Soo-Mi Rhee focuses her practice on economic sanctions laws, export control laws, antibribery laws, antiboycott laws, customs laws, and other foreign policy, national security, and economic policy-based trade and investment controls.

Ms. Rhee provides assistance with determining the export classification of products and technologies; obtaining commodity jurisdiction determinations; obtaining export licenses and other authorizations; determining the applicability of US economic sanctions laws to specific transactions; recognizing and negotiating antiboycott language in transaction documents; conducting due diligence in mergers and acquisitions, initial public offering and other investment/financing contexts; representing clients in administrative and criminal enforcement cases; conducting internal investigations, compliance reviews, and compliance audits; and developing and implementing internal compliance programs.

In addition, she assists clients with concerns regarding US national security-based foreign investment restrictions administered by the Committee on Foreign Investment in the United States (CFIUS). Ms. Rhee also advises clients on a wide range of US customs compliance matters, including the proper classification and valuation of imported merchandise, customs bond obligations, country of origin marking and government procurement requirements, Customs Trade Partnership Against Terrorism (CTPAT) membership requirements and Importer Security Filings rules.

In law school, Ms. Rhee was Executive Managing Editor of the Columbia Law Review and a Harlan Fiske Stone scholar.


  • Non-US financial institution in an ongoing US government-initiated investigation of potential US sanctions violations being conducted by SDNY, NYAG, NYDFS, NY Fed, and OFAC.
  • Multinational manufacturer in ongoing Petrobras FCPA/anticorruption “Car Wash” investigation being conducted by DOJ, SEC, and Brazilian authorities.
  • Oil and gas data processing company in self-reported DOJ, OFAC, and BIS investigation of potential violations of the FCPA, US economic sanctions, and US export controls.
  • Major medical device manufacturer in US government-initiated, multi-continent DOJ, OFAC, and BIS investigation of potential violations of US economic sanctions and US export controls.
  • General counsel of a major oil and gas company in US government-initiated, multi-continent DOJ, SEC, OFAC, and BIS investigation of potential violations of the FCPA, US economic sanctions, and US export controls.
  • Major financial institution in self-reported OAC investigations of potential violations US antiboycott laws.
  • Oil and gas company in self-reported DOJ and SEC investigation of potential violations of the FCPA.
  • Fortune 100 defense contractor in self-reported DDTC investigations of potential violations of US export controls.
  • Logistics company in self-reported OFAC investigation of potential violations of US export controls.
  • Private equity funds in conducting internal anti-corruption, economic sanctions, and export controls audits of newly acquired portfolio companies.


Case Study: Cross-Border Investigations in China and Brazil
Panelist, GIR Live Sanctions, Export Control and National Security Conference, Washington, DC
Global Anti-Corruption Insights: Summer 2019
Update on Recent Enforcement, Litigation, and Compliance Developments
OFAC Now Requires U.S. Persons to Report Any Transaction They Reject Due to Sanctions
Not as Close to the Vest: OFAC Releases a "Framework" for Sanctions Compliance that Offers a Glimpse into the Agency's Enforcement Posture
Turnabout: Preparing for the Trump Administration's New Cuba Restrictions and Lawsuits on "Trafficking" in Confiscated Property


  • JD, Columbia Law School, 2002
  • MPA, Princeton University, 1998
  • BA, Yonsei University, 1996
  • District of Columbia
  • New York
  • US Court of Appeals for the Federal Circuit
  • US Court of International Trade
  • Not licensed as a Foreign Legal Consultant in Korea

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