Sandra Jorgensen is an associate in the International Trade Practice, with a particular focus on national security, including export controls and economic sanctions regulations, and reviews before the Committee on Foreign Investment in the United States (CFIUS).
In her sanctions and export controls practice, Sandy advises on the laws and regulations administered by the US Department of Treasury's Office of Foreign Assets Control (OFAC), the US Department of Commerce's Bureau of Industry and Security (BIS) and the US State Department's Directorate of Defense Trade Controls (DDTC). She provides clients in a wide range of industries with compliance advice on US primary, secondary, and sectoral sanctions programs against Iran, Russia, Venezuela, Syria, Sudan, Cuba, North Korea, and the Crimea region of Ukraine, as well as on matters involving designated parties on OFAC's Specially Designated Nationals and Blocked Persons List (SDN List). She also advises on classification and licensing requirements and restrictions under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR).
Beyond compliance advice, Sandy also conducts sanctions and export control-related due diligence and assists with internal investigations of possible sanctions and export control violations, as well as assisting companies with Voluntary Self-Disclosures (VSD) to relevant government agencies.
In her CFIUS practice, Sandy represents clients in Exon-Florio reviews and investigations before CFIUS as well as regarding foreign ownership, control or influence (FOCI) mitigation matters.
Sandy also has experience in international trade remedies litigation, representing clients in antidumping and countervailing duty cases before the US Court of International Trade, US Court of Appeals for the Federal Circuit, and the Department of Commerce.
Prior to joining White & Case, Sandy worked at another law firm in Washington, DC, where she specialized in international trade and CFIUS matters.
Representative Export Control Matters
Assisted with internal investigations in support of Voluntary Self-Disclosures to BIS of potential export control violations for companies in the technology and internet-based services sector.
Advised engineering, aerospace, information technology, and defense companies on compliance with respect to the ITAR, including with regard to work under Technical Assistance Agreements (TAAs) and Manufacturing Licensing Agreements (MLAs) to export technical data related to defense and military-related articles.
Assisted in the preparation of export control compliance programs for the defense industry, tech industry, semiconductor industry and oil & gas industry.
Advised clients in the aviation, manufacturing, semiconductor, software, technology, oil & gas, medical device, and defense industries on appropriate export control classification numbers (ECCN) of goods and services, applied for commodity classifications requests (CCATS) and export licenses, and advised on applicable restrictions on exports.
"CFIUS Update: Proposed Changes to Critical Technology Mandatory Filing Requirements; 2018-2019 Statistics Show Key Trends; CFIUS Implements New Case Management System," White & Case Client Alert, May 28, 2020 (co-author)
"US Commerce Department Increases Scrutiny and Restrictions on Exports with Particular Focus on China, Russia and Venezuela," White & Case Client Alert, May 4, 2020 (co-author)
"Bureau of Industry and Security Issues First 'Emerging Technology' Control on Artificial Intelligence-Based Geospatial Imagery Software," White & Case Client Alert, February 7, 2020 (co-author)
"CFIUS Finalizes New FIRRMA Regulations," White & Case Client Alert, January 22, 2020 (co-author)
"Foreign Investment Review Heats Up Following CFIUS Reform," Bloomberg Law, October 28, 2019 (co-author)
"US Designates Huawei to Entity List, Issues Temporary General License," White & Case Client Alert, May 23, 2019 (co-author)
"US Targets Telecommunications Transactions Involving the Information and Communications Technology and Services Supply Chain," White & Case Client Alert, May 17, 2019 (co-author)
"Department of Commerce Review of Export Controls on Emerging Technologies," White & Case Client Alert, November 28, 2018 (co-author)
"CFIUS: FIRRMA Pilot Program Mandates Notification for Certain Critical Technology Transactions," White & Case Client Alert, October 13, 2018 (co-author)
"US Expands Russian Defense and Intelligence Sanctions, Targets Chinese Parties," White & Case Client Alert, September 26, 2018 (co-author)