A trusted adviser to major corporations facing high-stakes criminal and regulatory investigations, Soo-Mi Rhee offers extensive experience in major anti-corruption, compliance, national security, and export controls and sanctions issues, with particular expertise in high-tech industries. Ms. Rhee helps companies and institutions establish compliance programs, obtain export authorizations, obtain product classifications, conduct compliance risk assessments/audits, and conduct internal investigations. She also regularly represents clients in economic sanctions, export controls, and/or Foreign Corrupt Practices Act (FCPA) enforcement proceedings before the Office of Foreign Assets Control, US Department of the Treasury (OFAC), the Bureau of Industry and Security, US Department of Commerce (BIS), the Directorate of Defense Trade Controls, US Department of State (DDTC), US Department of Justice (DOJ) and/or US Securities and Exchange Commission (SEC).

In addition, Ms. Rhee assists clients with concerns regarding US national security-based foreign investment restrictions administered by the Committee on Foreign Investment in the United States (CFIUS).

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

Experience

  • International financial institution in an ongoing US government-initiated investigation of potential US sanctions violations being conducted by SDNY, NYAG, NYDFS, FRBNY, FRBSF, and OFAC.
  • Global shipbuilder in Petrobras FCPA/anti-corruption "Car Wash" investigation 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.
  • Global airline company in an internal investigation of potential US economic sanctions violation.
  • Defense component reseller in an investigation initiated by CBP and DHS of potential US export controls.
  • Global pharmaceutical company in leading an anti-trust and anti-corruption internal investigation related to a criminal proceeding outside the United States.
  • Technology company in an internal investigation related to a potential diversion of company’s products to sanctioned countries, as well as assisting the company in responding to an OFAC subpoena.
  • Global Fortune 20 consumer electronics and telecommunications company in conducting a global FCPA/anti-corruption compliance risk assessment.
  • Fortune 200 IT services company in conducting a global FCPA/anti-corruption compliance risk assessment.
  • 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 FCPA/anti-corruption, economic sanctions, and export controls audits of newly acquired portfolio companies.

Recognition

Global Investigations Review
Women in Investigations (2021)

Credentials

Education
  • JD, Columbia Law School, 2002
  • MPA, Princeton University, 1998
  • BA, Yonsei University, 1996
Admissions
  • 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
Overview

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