Trade Regulation, Export Controls & Sanctions

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Proposed CFIUS Rules Affirm Evolution and Growth of Review Process, Expansion of Penalties [Alert]

The Committee on Foreign Investment in the United States (CFIUS) issued a proposed update expanding its mitigation and enforcement provisions and increasing the maximum penalties.

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Cozen O’Connor provides comprehensive international trade services, allowing our clients to focus on their business objectives instead of worrying about navigating compliance with trade control laws and regulations that are ever-changing in response to world events.

Our attorneys advise clients on all facets of U.S. trade sanctions and export controls, including Export Administration Regulations, International Traffic in Arms Regulations, and various economic sanctions programs administered by OFAC. We frequently counsel clients regarding export licensing, commodity classification, anti-boycott regulations, and trade restrictions involving embargoed countries and sanctioned individuals and entities. We advise clients on U.S. Customs regulations relating to duties and tariffs, documentation requirements, contraband, cargo clearance, and supply-chain security.

We have a diverse group of clients who seek advice on trade regulation, export controls, and sanctions, and we represent clients at all stages in the life cycle of a transaction. We work with ocean and inland carriers, technology companies, manufacturers, global shippers, and individual executives, both U.S. and non-U.S., in connection with U.S. and international trade regulations.

Cozen O’Connor attorneys routinely perform high-level audits, design compliance policies, provide on-site training, and advise on major transactions. We help clients respond to trade incidents or government inquiries, lead internal investigations of potential violations, and assist with voluntary disclosures. When necessary, we handle major government investigations and enforcement actions, appeals of agency decisions to the courts, and criminal and civil litigation.

Cozen O’Connor attorneys work with the full range of federal agencies that oversee U.S. trade policy, including the Bureau of Industry and Security, Office of Foreign Assets Control (OFAC), Customs and Border Protection and the Directorate of Defense Trade Controls.

 

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Experience

Publications

State Department Proposes Amendment to ITAR, Aiming to Bolster AUKUS Partnership [Alert]

May 02, 2024

The U.S. State Department's proposed rule would reduce International Traffic and Arms Regulations (ITAR) licensing requirements for the transfer of defense articles or services between the U.S., Australia, and the U.K.

Proposed CFIUS Rules Affirm Evolution and Growth of Review Process, Expansion of Penalties [Alert]

April 12, 2024

The Committee on Foreign Investment in the United States (CFIUS) issued a proposed update expanding its mitigation and enforcement provisions and increasing the maximum penalties.

With Signs of Enforcement on Horizon, CFIUS Releases Penalty Guidelines

October 24, 2022

CFIUS' new set of guidelines point to a potentially heightened enforcement environment in their efforts to protect U.S. national security interests.

Biden Administration Significantly Expands CFIUS National Security Factors [Alert]

September 21, 2022

President Biden signed an Executive Order connecting the work of the CFIUS to national security aims beyond the traditional defense industrial base.

Section 301 Petition Concerning Mexican Agricultural Products Filed [Alert]

September 15, 2022

On Sept. 8, Florida lawmakers filed a petition with USTR seeking relief for an alleged Mexican export targeting scheme.

Managing Supply Chain Consequences Of Russian Sanctions

April 13, 2022

Heather Marx and Kristi Zentner contributed an article to Law360 discussing how President Joe Biden has issued executive orders restricting trade with Russia and has revoked Russia's permanent normal trade relations.

U.S. Responds to Russian Invasion of Ukraine with Costly Sanctions [Alert]

March 07, 2022

Bob Magovern, Wayne Rohde, and Rachel Welford discuss the series of unprecedented economic sanctions and export controls designed to prevent President Vladimir Putin from raising capital to fund its invasion of Ukraine.

OFAC Amends and Reissues More Comprehensive Somalia Sanctions Regulations [Alert]

May 03, 2021

Rachel Welford, Robert Magovern and Wayne Rohde discuss OFAC's reissued Somalia Sanctions Regulations, which incorporate executive orders from 2010.

U.S. Announces Sweeping New Sanctions Targeting Russia [Alert]

April 21, 2021

Wayne Rohde, Robert Magovern and Matthew Howell discuss Executive Order 14024 imposing new sanctions on the Russian Federation in response to foreign election interference in the 2020 U.S. federal election and the SolarWinds cyberattack aimed at various U.S. federal agencies.

Happy Cybersecurity Awareness Month: OFAC and FinCEN Issue New Advisories on Ransomware Payments [Alert]

October 08, 2020

Don Kassilke and Katie Sobotta discuss the two new advisories from OFAC and FinCEN on ransomware attacks.

Up in Smoke: OFAC Further Erodes Obama-Era Cuba Rules [Alert]

September 29, 2020

Don Kassilke and Rachel Welford discuss OFAC's amended the Cuban Assets Control Regulations (CACR) to further restrict U.S. engagement with Cuba in order to deny revenue to the Cuban regime.

Resolutions Highlight Aggressive Sanctions Enforcement, Need For Senior Level Commitment to Compliance [Alert]

July 21, 2020

Gordon Yehudah and Martin Bloor discuss the U.S. Department of the Treasury’s Office of Foreign Assets Control's settlement with Essentra FZE Co. Ltd., for alleged violations of the North Korea Sanctions Regulations.

Amid Global Supply Concerns, Trump EO Seeks to Increase Domestic Fishing and Aquaculture Production [Alert]

May 20, 2020

Jeff Vogel, Matt Howell, and Anne Mickey discuss the Executive Order on Promoting American Seafood Competitiveness and Economic Growth that seeks to reduce the need for imported seafood, which makes up roughly 85 percent of consumption in the United States.

FEMA Issues Further Guidance on PPE Exports [Alert]

April 22, 2020

Don Kassilke and Wayne Rohde discuss FEMA's additional guidance about the 10 categories of PPE exports that would be exempt from the recent, temporary ban.

OFAC Publishes Fact Sheet on Humanitarian Assistance to Sanctioned Countries [Alert]

April 20, 2020

Don Kassilke, Wayne Rohde, and Kathryn Sobotta discuss OFAC's recently release Fact Sheet detailing regulatory requirements relevant to export humanitarian goods to sanctioned countries such as Iran, Venezuela, North Korea, Syria, Cuba, Ukraine, and Russia.

U.S. to Prohibit the Export of Certain Personal Protective Equipment

April 10, 2020

Don Kassilke and Wayne Rohde discuss FEMA's anticipated temporary final rule prohibiting certain exportation of PPE, including N95 respirators, surgical masks, and exam and surgical gloves.

Events & Seminars

Past Events

ESG In The International Trade And Supply Chain

March 21, 2024 - Washington, D.C.

59th Annual Inter-American Bar Association Conference

December 01, 2023 - Rio de Janeiro, Brazil

Mexican Labor and USMCA’s Rapid Response Mechanism

October 20, 2023 - Cleveland, OH

Labor Rights and the USMCA

September 20, 2023 - Mexico City, Mexico

In The News

Eleven Cozen O’Connor Attorneys Recognized as Washington, D.C., Super Lawyers and Rising Stars

April 22, 2024

Seven attorneys were recognized as Super Lawyers and four were named Rising Stars, a list that recognizes attorneys under the age of 40.

Cozen O’Connor Recognized as a “Best Law Firm” in 30 Practice Areas Nationwide, 115 Practice Areas Regionally

November 30, 2022

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 30 practice areas nationwide and 115 practice areas regionally.

Russian Cargo Ships Spotted 'Going Dark' to Evade Sanctions

March 28, 2022

Neil Quartaro was quoted in an article published by Voice of America which discusses how Russian tanker ships carrying oil and petroleum products have been observed turning off systems that broadcast their identity and location, which is often associated with efforts to evade sanctions.

Four Cozen O’Connor Attorneys Recognized in 2022 Chambers Global Rankings

February 17, 2022

Chambers Global has recognized four Cozen O’Connor attorneys: Susan Eisenberg (Miami – Labor & Employment), Geoffrey Ferrer (New York – Transportation & Trade), Shane Hardy (Toronto – Intellectual Property), and Joseph Tilson (Chicago – Labor & Employment), as worldwide leaders in their respective practices.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

November 04, 2021

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 29 practice areas nationwide and 121 practice areas regionally.

Stephen Cozen and Stephen Miller Recognized as 2021 Best of the Bar Honorees by The Philadelphia Business Journal

October 06, 2021

Cozen O’Connor is pleased to announce that the Philadelphia Business Journal will honor Stephen Cozen and Stephen Miller at its fifth annual Best of the Bar Awards.

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 19, 2021

Best Lawyers selected 210 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2022 edition of The Best Lawyers in America.

Legal 500 Recognizes Six Cozen O’Connor Practice Areas and 12 Cozen O'Connor Attorneys in its 2021 Legal Guide

June 17, 2021

The Legal 500 United States named Cozen O’Connor’s Aviation, Construction, Immigration, Insurance, and Maritime practices and Cozen O’Connor attorneys Scott Bettridge, Raymond DeLuca, Geoffrey Ferrer, Bruce Ficken, David Heffernan, Jeffrey Lawrence, Robert Magovern, Anne Mickey, Jeffrey Mullen, Josh Stein, Jeff Vogel, and Rachel Welford to its 2021 Legal Guide.

JD Supra Selects Four Cozen O’Connor Attorneys as Top Authors

April 05, 2021

Cozen O’Connor is pleased to announce that Bernard Nash and Lori Kalani, co-chairs of the firm’s State Attorneys General practice, Michael Schmidt, vice chair of the firm’s Labor & Employment Department, and Rachel Welford, an attorney in the firm’s Transportation & Trade Group have been selected as top authors for JD Supra’s 2021 Readers’ Choice Awards for their thought leadership on key topics during 2020.

200 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 20, 2020

Best Lawyers selected 200 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2021 edition of The Best Lawyers in America© (Copyright 2020 by Woodward/White, Inc., of Aiken, SC).

Legal 500 Recognizes Six Cozen O’Connor Practice Areas and 13 Cozen O'Connor Attorneys in its 2020 Legal Guide

June 22, 2020

The Legal 500 United States named Cozen O’Connor’s Aviation, Construction, Immigration, Insurance, and Maritime practices and Cozen O’Connor attorneys Scott Bettridge, Stephen Cozen, Raymond DeLuca, Geoffrey Ferrer, Bruce Ficken, David Heffernan, Jeffrey Lawrence, Robert Magovern, Anne Mickey, Jeffrey Mullen, Josh Stein, Christopher Sweeney, and Jeff Vogel to its 2020 Legal Guide.

People

Awards

Cozen O’Connor Recognized as a “Best Law Firm” in 30 Practice Areas Nationwide, 115 Practice Areas Regionally

November 30, 2022

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 30 practice areas nationwide and 115 practice areas regionally.

Four Cozen O’Connor Attorneys Recognized in 2022 Chambers Global Rankings

February 17, 2022

Chambers Global has recognized four Cozen O’Connor attorneys: Susan Eisenberg (Miami – Labor & Employment), Geoffrey Ferrer (New York – Transportation & Trade), Shane Hardy (Toronto – Intellectual Property), and Joseph Tilson (Chicago – Labor & Employment), as worldwide leaders in their respective practices.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

November 04, 2021

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 29 practice areas nationwide and 121 practice areas regionally.

Stephen Cozen and Stephen Miller Recognized as 2021 Best of the Bar Honorees by The Philadelphia Business Journal

October 06, 2021

Cozen O’Connor is pleased to announce that the Philadelphia Business Journal will honor Stephen Cozen and Stephen Miller at its fifth annual Best of the Bar Awards.

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 19, 2021

Best Lawyers selected 210 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2022 edition of The Best Lawyers in America.

Legal 500 Recognizes Six Cozen O’Connor Practice Areas and 12 Cozen O'Connor Attorneys in its 2021 Legal Guide

June 17, 2021

The Legal 500 United States named Cozen O’Connor’s Aviation, Construction, Immigration, Insurance, and Maritime practices and Cozen O’Connor attorneys Scott Bettridge, Raymond DeLuca, Geoffrey Ferrer, Bruce Ficken, David Heffernan, Jeffrey Lawrence, Robert Magovern, Anne Mickey, Jeffrey Mullen, Josh Stein, Jeff Vogel, and Rachel Welford to its 2021 Legal Guide.

JD Supra Selects Four Cozen O’Connor Attorneys as Top Authors

April 05, 2021

Cozen O’Connor is pleased to announce that Bernard Nash and Lori Kalani, co-chairs of the firm’s State Attorneys General practice, Michael Schmidt, vice chair of the firm’s Labor & Employment Department, and Rachel Welford, an attorney in the firm’s Transportation & Trade Group have been selected as top authors for JD Supra’s 2021 Readers’ Choice Awards for their thought leadership on key topics during 2020.

200 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 20, 2020

Best Lawyers selected 200 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2021 edition of The Best Lawyers in America© (Copyright 2020 by Woodward/White, Inc., of Aiken, SC).

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