White Collar Defense & Investigations

Export and Trade

We have extensive experience over many years in all aspects of export and import control law and regulation. Our firm has represented clients in criminal or enforcement investigations arising under the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), the International Emergency Economic Powers Act (IEEPA), and the Trading with the Enemy Act, as well as other laws that affect export licensing decisions. On the other side of international trade, we have represented corporations under investigation for violations of US Customs regulations relating to imports, including, for example, a foreign corporation subject to a grand jury investigation for allegedly improperly importing millions of dollars of merchandise. Our experience extends to dealings with the Departments of Justice, Commerce, State, Treasury and Energy, NASA, and the Nuclear Regulatory Commission.


  • Major company under investigation for alleged export violations.
  • Software company in an investigation into allegedly improper imports.
  • Defense and security company charged with export violations in regulatory and legislative arenas.
  • Academic research institution in criminal and administrative investigation into alleged violations select agent and toxin regulations (no charges were brought).
  • Companies and individuals in criminal proceedings and in enforcement and licensing proceedings before OFAC, in connection with Iran sanctions.
  • Tried four-week federal criminal case in the Southern District of New York for client charged with violating the OFAC Iran sanctions; primary counts of conviction reversed on appeal.
  • Major life sciences company in a complex, multi-national criminal and civil investigation concerning an alleged US trade sanction and other violations involving sales in the Middle East and Africa before multiple US government agencies.
  • United States v. Arnold Bengis et al., Headed investigation and prosecution of international bribery, fish poaching and smuggling scheme. Successfully argued government appeal of district court's order denying restitution to South Africa, resulting in a groundbreaking court of appeals decision on the rights of victims of environmental crime, and the largest Lacey Act restitution award in United States history. United States v. Bengis et al., 07-4895-cr 2d Cir. (Jan. 4, 2011).

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