International Trade

Sanctions Compliance (OFAC)

When international businesses need guidance on sanctions compliance, require due diligence on potential partners, customers, suppliers, and investment targets, seek representation in response to sanctions-related directed disclosures by U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and other agencies, or intend to reverse sanctions designations (whether primary or secondary), they turn to Fluet for sophisticated and informed advocacy. Sitting at the intersection of U.S. foreign policy and international commerce, our International Trade team provides expert guidance on compliance with the U.S. Government’s complex web of economic and trade sanctions and, in particular, those implemented by OFAC.

Leveraging a deep understanding of the U.S. Government’s economic and trade sanctions apparatus, Fluet attorneys assists clients by:

  • Analyzing international transactions for sanctions exposure.
  • Conducting due diligence on customers, investors/acquirers, officers, directors, suppliers, manufacturers, consultants, brokers, and local representatives for sanctions-related “red flags.”
  • Drafting “specific license applications” that seek authorization from OFAC to engage in otherwise prohibited transactions.
  • Developing directed and voluntary disclosures of sanctions violations and negotiate administrative settlements.
  • Conducting internal investigations and audits to identify sanctions violations or verify the lack thereof.
  • Petitioning OFAC and other agencies for the “de-listing” of individuals and entities.

International Trade Co-Chairs

Our attorneys are adept at both structuring and negotiating international transactions and managing the regulatory risks that are unique to global operations, all while leveraging a deep understanding of U.S. foreign policy and U.S. national security interests.