As Co-Chair of Fluet’s International Trade Practice, Adam Munitz advises U.S. and foreign clients on export controls, economic and trade sanctions, filings with the Committee on Foreign Investment in the United States (CFIUS), mitigation of foreign ownership, control, or influence (FOCI), and the Foreign Corrupt Practices Act (FCPA).

For over a decade, Mr. Munitz has supported clients across the defense, security, and intelligence sectors, drawing upon his practical understanding of U.S. foreign policy, trade policy, and national security policy to deliver practical solutions to highly complex problems.

In the area of export controls, he provides the full suite of services to defense contractors and brokers participating in direct commercial sales of arms and military hardware, advising them on export classification under the International Traffic in Arms Regulations and the Export Administration Regulations, export licensing, the implementation of customized compliance programs, responses to directed disclosures from the Directorate of Defense Trade Controls at the U.S. Department of State and the Bureau of Industry and Security at the U.S. Department of Commerce, and more.

Across a wide variety of sectors, Mr. Munitz advises U.S. and foreign individuals and entities on compliance with U.S. economic and trade sanctions, focusing principally on those implemented by the Office of Foreign Assets Controls (OFAC) at the U.S. Department of the Treasury. He has advised on the full spectrum of economic and trade sanctions-related objectives, including sanctions compliance, sanctions due diligence, applications for “specific licenses,” responses to directed disclosures and subpoenas, and “de-listing” petitions in response to sanctions designations.

For his clients exploring mergers and acquisitions, he provides comprehensive guidance on filings with CFIUS and FOCI mitigation by identifying risks and requirements, evaluating transactions for CFIUS and FOCI triggers, obtaining CFIUS approvals on behalf of foreign buyers and domestic sellers, and negotiating novel FOCI mitigation instruments with the Defense Counterintelligence and Security Agency (DCSA) on behalf of cleared companies and foreign investors and acquirers.

Representative Matters

• Advised a manufacturer of an advanced Unmanned Aerial System on its temporary and permanent exports to the Middle East.
• Obtained approval of multiple export license applications on behalf of a defense contractor in furtherance of U.S. government contracts.
• Petitioned U.S. Customs and Border Protection for the release of aircraft seized at multiple ports.
• Advised a defense contractor on the sale of lethal hardware to Southeast Asia and obtained the requisite export licenses from DDTC and BIS.
• Guided a broker of lethal arms through the broker licensing process.
• Represented a foreign importer of lethal arms and military platforms.
• Advised a manufacturer of an Unmanned Aerial System on its sales to Ukraine.
• Navigated U.S. sanctions on behalf of a foreign luxury goods manufacturer.
• Advised a U.S. consulting firm on its sale of military aircraft to East Africa.
• Successfully defended the executive of a U.S. Government contractor against a proposed debarment by the Department of the Navy.
• Advised a Middle Eastern logistics company on its expansion into the U.S. Federal market.
• Advised a Canadian aerospace company on its U.S. investments, which included the successful negotiation of a novel FOCI mitigation instrument, and its aircraft procurement strategy.
• Advised a Middle Eastern aviation company on its response to an investigation by the U.S. Department of Commerce.
• Counseled a Southern African national on his designation by OFAC.
• Obtained multiple export license applications on behalf of a defense contractor exporting lethal arms and training services to Southeast Asia.
• Navigated the CFIUS approval process on behalf of a European optics company as it divested its U.S. subsidiary.
• Advised a provider of manned and unmanned ISR services on its export of sophisticated aircraft solutions to the Middle East.
• Obtained export licenses on behalf of a U.S. aerospace company expanding into the Middle East.
• Advised a U.S. broker on its brokering of lethal arms to the Middle East and its brokering license obligations.
• Counseled a telecommunications company on its Middle East operations.
• Navigated the CFIUS approval process on behalf of a foreign acquirer during its acquisition of a U.S. maritime company.
• Advised a private equity firm with foreign financing on its proposed acquisition of an unmanned aerial system manufacturer.
• Advised an aircraft parts reseller on its operations in the Kingdom of Saudi Arabia.
• Represented an arms broker during his investigation by the Directorate of Defense Trade Controls.
• Advised a contractor in the chemical, biological, radiological, and nuclear services sector on FOCI mitigation.
• Counseled a manufacturer of advanced communication hardware on its international expansion strategy.
• Navigated a U.S. company through a series of directed disclosures by the U.S. Government.
• Navigated the CFIUS approval process on behalf of a U.S. solar company as it sought to sell assets to East Asian buyers.
• Successfully resolved an extended directed disclosure aimed at a U.S. defense contractor operating in the Middle East.
• Advised a lethal arms manufacturer on its sales to the Middle East.
• Navigated a foreign aerospace company through the FOCI mitigation process resulting from a U.S. acquisition.
• Advised a U.S. nonprofit operating in Africa on its export licensing obligations.
• Successfully resolved a directed disclosure aimed at a U.S. lethal arms manufacturer.

Education

• J.D., George Mason University School of Law
• B.A., The George Washington University, magna cum laude, Phi Beta Kappa

Certifications + Licenses

• Virginia Bar