Export Controls, Economic Sanctions, and Antiboycott Rules
|Wiltshire & Grannis counsels companies regarding compliance with U.S. and
multilateral economic sanctions and export controls and represents them
before a variety of agencies to obtain licenses necessary to consummate
investment, financial, and export transactions.These agencies include:
the Department of the Treasury's Office of Foreign Assets Control
("OFAC"); the Department of Commerce's Bureau of Industry and Security
("BIS"); the Department of State's Directorate of Defense Trade
Controls ("DDTC"), Office of Terrorism Finance and Sanctions Policy,
and regional bureaus; and the Department of Defense Security Service
("DSS") and Defense Information Systems Agency ("DISA"). Wiltshire & Grannis also conducts internal investigations in this area and has
successfully defended clients in enforcement proceedings.
| Representative Matters|
- Advised large international services companies on policies,
procedures, and monitoring to ensure compliance with export controls
and economic sanctions .
- Forcefully challenged charges of export control violations,
avoiding major penalties and achieving a policy reversal that removed a
regulatory bar to the client's core business.
- Obtained the fastest-ever waiver of statutory bar on infrastructure
projects with any Iranian involvement and obtained timely OFAC license.
- Conducted a major transnational internal investigation of potential
trade control violations for a public company's audit committee, and
orchestrated voluntary self-disclosures to OFAC and BIS with very
- Represented infrastructure provider in obtaining an OFAC license
permitting an infrastructure project in Sudan, including a successful
appeal before the interagency Operating Committee chaired by BIS.
- Successfully represented project developer in interagency process
to obtain an export license to construct a chemical plant in the Middle
East, where initial license application had been denied prior to
engagement of Wiltshire & Grannis.
- Successfully represented non-governmental organization in obtaining
OFAC licenses to conduct scientific and educational activities in Cuba.