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32 WorldECR www.worldecr.com

While some professionals maybemoan the quotidianregularity of their jobs, one

senses sometimes that those in ourfields wouldn’t mind a dose of it – justto break the routine of unpredictability.I exaggerate. In reality, we know thatfor trade compliance people, managingchange – corporate, legal, geopolitical,technological – is very much whatdrives them.

Uncertainty and surprise create theconditions that are conducive inbringing out their expertise, trainingand professional instincts. Both havebeen much in evidence in the past year:a radically different US administration,the drawing to a close of Export ControlReform, great uncertainty over the stateof play of sanctions regimes againstIran, Cuba and Russia, and the generaltrajectory of foreign policy.

We received some really stunningsubmissions for many of the categoriesin this year’s Awards across all thespectrums – from private practice andindustry but also government – and wethink there’s a lot to learn from theinsight the Awards give us into thenature of what really happens in theworld of export controls and sanctions.

For compliance professionals at thetop of their game, excelling meanshelping their client companies takeadvantage of opportunities that exist,not closing them down in the face ofonerous red-tape – but all the whileunderstanding and abiding by not onlythe letter of the law, but the underlyingrationale, the policy decisions andethical considerations that guided thedrafting hand. These people,frequently, are the unsung heroesbehind many corporate successes.

Other lessons to draw from theawards: size isn’t everything! We knowthat there is compliance excellence tobe found in law firms which number ahandful of partners who happen to haveeschewed ‘big firm’ life, just as there isin companies which may struggle todescribe themselves as ‘multinational’.The veritable (and enviable) youth ofmany of those put forward shows usalso that, perhaps more so each year,trade compliance is regarded as an

exciting profession, attracting fineyoung minds looking to put their‘Millennial’ skills to work (and itcertainly provides that opportunity.)

And a final observation. There is areal sense of community in the tradecompliance world. Yes, their employersor firms may be closely looking atcorporate or legal rankings, but there’sa genuine desire amongst theWorldECR constituents for sharingbest practice and experience (even ifkeeping the ‘secret sauce’ ingredients tothemselves).

Thank you to everyone whocontributed submissions, responded toour follow-ups, and generally abidedwith us. And as in previous years, we’reparticularly grateful to our Panel ofJudges for the time they generouslyafforded us, and the acumen theyexercised whilst doing so.

Tom Blass

Editor, WorldECR

AWARDS 2017The WorldECR Awards recognise the achievement of export controls and sanctions professionals.

WorldECR Awards 2017 WorldECR Awards 2017

Supported by



Winner: Kevin Wolf

There are few people in the exportcontrols and sanctions space whosename is as well known as our ExportControl Practitioner of the Year,Kevin Wolf. The central strategist,negotiator and implementer ofPresident Obama’s Export ControlReform Initiative, Wolf served forseven years as Assistant Secretary ofCommerce for Export Administrationbefore joining Akin Gump’s DC officein January this year.

WorldECR readers know all aboutthe Export Control Reform (‘ECR’)initiative – few have been untouchedby the overhaul of US export controlsundertaken on Wolf’s watch. ‘Thereform initiative was a massive,seven-year interagency effort tosubstantially rewrite the defence tradeand most dual-use export controls toaccomplish various national securityand foreign policy objectives,’ notesWolf’s new firm. ‘The reform resultedin the transfer to the CommerceDepartment from the StateDepartment of responsibility forregulating most direct commercialdefence trade transactions. As a resultof these efforts, most of the newcontent of the EAR and the ITARreflects strategic direction, policygoals and negotiations between Mr.Wolf and other agencies. In addition,he led the communication effortsinvolved in rolling out andimplementing the new system, whichincluded outreach to US and foreigncompanies, foreign governments andother US government departmentsand agencies.’

As one of our judges commented,‘Kevin deserves recognition. Heworked tirelessly while at BIS toadvance export control reform, as wellas to make himself endlesslyaccessible to exporters andpractitioners.’

In addition to his efforts with theECR initiative, during his tenure atthe Department of Commerce Wolfserved as the primary CommerceDepartment senior official responsiblefor working with the interagencyCommittee on Foreign Investment inthe United States (‘CFIUS’) and wasresponsible for, among other things:

l administering a licensing systemthat processes nearly 40,000licence applications and othersubmissions a year

l resolving an array of disputes withother government agencies andexporters

l working with law enforcementofficials on investigations andenforcement matters and policy

l setting licensing and other policiescovering an array of countries,end-users and end uses

l working with industryrepresentatives and foreigngovernments on various US andmultilateral policy, regulatory andenforcement issues

Finally, we note Wolf’s reputationfor willingness to engage withindustry during his tenure in publicservice. It was Wolf’s team thatworked with Clifford Chance to find asolution and settlement for Chinesetelecoms giant ZTE after beingdesignated for violating US exportcontrols – a matter which we focus onelsewhere this issue.

All in all, there is no doubt thatKevin Wolf has had a tremendousimpact on the field of export controls.He is a worthy winner

Runner-Up: Rosie Petrov,

Runner-up is Rossitza (Rosie)Petrov, Program Manager, Office ofExport Control Cooperation, Bureauof International Security andNonproliferation, US Department ofState.

Ms Petrov is responsible for theadministration of the Export Controland Related Border Security (‘EXBS’)Program, which helps partnergovernments establish nationalstrategic trade control systems thatmeet international standards andcultivate sustainable capabilities todetect, interdict, investigate, andprosecute illicit transfers of weaponsof mass destruction (‘WMD’), WMD-related items, and conventional arms.

Ms Petrov’s portfolio includes theEXBS Graduate Partners, whichcomprise 12 recent members of theEuropean Union (Bulgaria, CzechRepublic, Cyprus, Hungary, Latvia,Lithuania, Malta, Poland, Romania,Slovakia, and Slovenia).

In 2016, Ms Petrov undertookseveral results-oriented initiativesthat sought to enhance the value ofexport controls to the broadercommunity.

These included:

Export Control Practitioner of the Year

Kevin Wolf

‘He worked tirelessly while at BIS to advance

export control reform, as well as to make himself

endlessly accessible to exporters and

practitioners.’

Rosie Petrov

Ms. Petrov has driven a range of training and mentoring

initiatives internationally, all focused on improving export

control compliance and combating proliferators.



l Sponsoring a research project bythe Stockholm International PeaceResearch Institute (‘SIPRI’)designed to examine exportcompliance guidelines andpractices among and across EUMember States.

l Spearheading the effort to updatecontent and improve operability oftwo online tools. The first toolprovides support to the privatesector in development andimplementation of internalcompliance programmes. Thesecond tool provides support tofront-line border security officersin identifying suspiciouscommodities of proliferationconcern. Several countries inEurope and Southeast Asia haveexpressed interest in the ICPelectronic tool.

In addition, Ms Petrov has driven arange of training and mentoringinitiatives internationally, all focusedon improving export controlcompliance and combatingproliferators.

Rosie Petrov is a fine example ofthe truly valuable export controlspractitioner whose work, while notalways in the limelight, should beprized and celebrated by the widercommunity. Her contribution tointernational security is significant.

Highly commended

Pete Heine is aDirector of the Centerfor Strategic Security atArgonne NationalLaboratory in Lemont,Illinois. He is currentlyalso seconded to the

World Customs Organisation (‘WCO’)as National Expert, Strategic TradeControl Enforcement. Heine’spersonal focus is on strategic dual-usetrade control, particularly in theadvancement of effective targetingstrategies for identifying high-riskshipments and the establishment oftraining programmes for exportcontrol enforcement personnel. TheCenter for Strategic Security helpsidentify, plan, and implementsolutions to forestall long-termsecurity threats, especially thoserelated to proliferation of strategicweapons or exploitation of criticalvulnerabilities. Its Proliferation andTrade Analysis Group monitors

proliferation-relevant emergingtechnologies to develop export controlapproaches and analyses strategictrade to identify proliferation risksand develop approaches for targetingand interdicting illicit shipments.

In June 2013, Heine was secondedto the WCO to help launch the WCO'sStrategic Trade Control Enforcement(‘STCE’) programme. For the WCO,he led the development of the STCEImplementation Guide and theassociated STCE training curriculum,and is now leading the effort toaccredit and certify worldwidecustoms trainers in the use of thecurriculum.

Marnix Somsen is apartner in the law firmof De Brauw BlackstoneWestbroek inAmsterdam and NewYork. In recent years, hehas enjoyed a good deal

of success for his clients in difficultmatters involving conflicting tradecontrols – specifically in mattersimpacted by US export controls andsanctions in their extraterritorialapplication and by the EU blockingordinance. This is a delicate balancingact, where a wrong step can provoke aregulator’s wrath and a client’sbusiness interests quickly unravelled.Somsen has developed two managedapproaches to the problem whichfocus on selecting the best andappropriate forum for disclosure andresolution of the matter. Employingthese methods, he has enjoyed successin some high-profile disputes forclients who include ING Bank – in asettlement with US authorities in adispute over US Cuba sanctions –and for Fokker Services in settlementagreements with the US Departmentof Justice, OFAC and BIS, relating tohistorical conduct involvingtransactions and customers insanctioned countries (Iran, Sudan andMyanmar).

Ajay Kuntamukkalais a partner in the DCoffice of Hogan Lovells.With over 17 years ofprivate sector andgovernment experience,he combines legal

analysis and policy advocacy to adviseclients on a range of export controls,sanctions, anti-boycott, nuclear trade,and encryption matters. He is a go-toadvisor for the nuclear industry on

export control matters, includingnuclear reactor suppliers, softwareand equipment suppliers, utilities,consulting firms, and insuranceproviders. He represents the NuclearEnergy Institute, the leading US tradeassociation for the nuclear industry,and participates in NEI’s ExportControl Subcommittee.

Currently, Ajay is leading a teamthat is assisting a large medical devicemanufacturer with trade controlsmatters arising out of the acquisitionand integration of a non-US companywith extensive US operations. Thisincludes integrating the seller’ssanctioned country business andother international business into theclient’s existing framework forsanctions, export controls, and anti-boycott compliance, and with duediligence and sanctions advice withregard to other acquisitions and jointventures involving Russia and Italy.The instruction included a review ofthousands of products for Irangeneral licence eligibility.

Judging panel and process

All submissions were reviewed by the

WorldECR team and a shortlist then

prepared for each award which was

given to our judging panel to make their

decisions upon. Judges were asked to

review the shortlists and choose a

winner and runner-up for each category

(excluding Export Controls Compliance

Team of the Year, Rest of the World and

Europe). Judges were given total

freedom as to how to prioritise the

various achievements of shortlisted

individuals and organisations in coming

to their decisions. Judges associated

with a shortlisted organisation were

deemed conflicted and unable to vote in

that category. Where the judges’

decisions resulted in a tie, the casting

vote would be that of the WorldECR

team.

The WorldECR team included Tom Blass,

editor, and Mark Cusick, publisher. Our

judging panel were:

Doug Jacobson, Partner, Jacobson

Burton Kelley PLLC; George Tan,

Principal, Global Trade Security

Consulting; Joshua D. Fitzhugh, Group

Head of Export Controls, BAE Systems

plc; Marian Niestedt, Partner, GvW Graf

von Westphalen; Maya Lester QC, Brick

Court Chambers; Meredith Rathbone,

Partner, Steptoe & Johnson llp; Pablo

Lecour, Partner, Deloitte; Richard

Tauwhare, Senior Director, Dechert llp;

Susanna Sjösten, Export Control

Director, Saab Kockums.

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Mac Fadlallah

‘has firmly planted himself as a leader

within the firm, helming its

international trade practice in Dubai.’

Winner: Yvo Amar

Together with Sebastiaan Bennink,Yvo Amar founded B&A Law in2014, having left one of the region’sleading law firms to focus exclusivelyon export controls and sanctions.From the beginning, Amar says, theiraim was ‘to become the number 1 lawfirm in the Netherlands in relation tosanctions and export controls’. It’sclearly very early days for the two-lawyer firm, but they have certainlyset off in the right direction.

In a short period, Amar has built aclient base drawn from a wide range ofindustry sectors, including companiesin mining, defence, drones andcommunications, and from a host offinancial institutions, advising onsanctions and export control matters.Some of his instructions have beenparticularly high profile. He success -fully represented the NPSA, the Dutchdelegation of the InternationalPractical Shooting Association, in agroundbreaking court case testingwhether the temporary export of thearms to a shooting competition fallswithin the scope of the EU armsembargo on Russia. The case wascovered by Dutch, Austrian andRussian press, and by WorldECR.

Demonstrating initiative and asavvy business sense, he joined thefirst Dutch trade mission to Iran,accompanied by the Dutch Minister ofEconomic Affairs. The missionfocused on oil and gas andagribusiness opportunities andincluded some of the largest Dutchcompanies, such as Air-France KLM,Philips, Unilever and Shell. Hisexperiences on the trip have enabledhim to build a network of contacts inindustry and also in the law andfinance in Iran as well as withEuropean businesses looking to take

advantage of new businessopportunities. A bright young man,going places.

Runner-Up: Mac Fadlallah

Mac Fadlallah, the youngest partnerat Akin Gump, must have bigshoulders. He made partner in 2017,but was already well used to theresponsibility that goes with the title.In 2012, Mac relocated from DC to thefirm’s office in Dubai, from where heruns a highly regarded trade practicefocused on the application of USexport controls and sanctions laws tonon-US entities, includingsubsidiaries of US companies.

Examples of Mac’s work includemanaging and successfully resolving alarge-scale investigation with criminalimplications for a global manufact -uring company, which involvedsite-visits to its Chinese manufact -uring plants to conduct de minimis

analyses, as well as raids of its Dubaisubsidiary to collect relevant data; andconducting legal feasibility studies onbehalf of non-US affiliates of UScompanies looking to launch businessoperations in Iran under GeneralLicense H. The firm categorises Mac’spractice as ‘unique’. Certainly, wedon’t know of many young lawyers

who can put on their CVs that theytrained the Ethiopian government onhow multilateral nonproliferationsanctions should factor into thecountry’s anti-money launderingframework, and then advise on thelegislation to give it effect.

Highly commended

Lindsey Roskopf is amember of the tradeteam at the Joiner LawFirm in Texas. Namepartner Jamie Joinersays of her: ‘Lindsey isin my experience truly

unique in her professional maturity,insights, and ability to apply the lawin a useful and practical manner toher client’s issues and concerns. Shehas operated at a level beyond heryears of experience since the verybeginning of her legal career.’ In thepast year, Lindsey has assistedcompanies in the oil and gas sectorthat include UK-based companieswith global operations in the US, Asia-Pacific, the Middle East and elsewhereon US sanctions and export controlinvestigations. She has also handledan OFAC investigation for a US-basedorganisation in the medical andacademic arena.

Roy Liu is a seniorassociate in the DCoffice of Hogan Lovells.In the past year, heserved as the lead seniorassociate for the firm’srepresentation of a

publicly traded Chinese manufacturerunder a US export enforcementinvestigation. The case wasparticularly challenging because of theEntity List designation of two entities

Young Practitioner of the Year

Yvo Amar

High-profile cases, strong business sense,

and an ambition to build a leading practice

mark him out for attention.


36 WorldECR WorldECR 36

within the company group, thecompany’s heavy reliance on US partsand components, and its complexcorporate structure and extensiveintra-company interactions. Royhelped the company through aninternal investigation, in establishinga compliance programme, and in itsdiscussions with US suppliers on thecontinuation of businessrelationships.

Arielle Boulanger-Houde, aClassification, ExportControls and CustomsSpecialist at SiemensCanada Limited, is achampion for export

control compliance in her ownorganisation and beyond. Despite heryoung age (not yet 30), she isregularly called upon to take part in

panel discussions where her insightand enthusiasm are highlyappreciated.

She has a ‘passion for her work’,her ‘enthusiasm for export control iscontagious and her positive attitude isinspiring,’ reports the ExportCompliance officer of anothercompany, who goes on to ask: ‘Howoften does it happen that your mentoris 16 years younger that you are?’

Winner: Clifford Chance

It is one of the biggest export controlstories of recent years. When Chinesetelecommunications company ZTECorporation (‘ZTE’) was placed on theBIS Entity List, effectively cutting itoff from its US suppliers andcustomers, Clifford Chance securedthe first ever ‘Temporary GeneralLicense’ (‘TGL’), enabling ZTE to stayin business during the pendency of amulti-agency export controlinvestigation.

Although ZTE received one of thelargest penalties ever imposed in thistype of case ($1.19bn), the resolutionwas founded upon Clifford Chancedemonstrating to the US agenciesinvolved that ZTE had turned thecorner, and that the company’scooperation and commitment tocompliance deserved a second chance.

Clifford Chance worked with ZTEto obtain multiple extensions of theTGL and secured ZTE’s removal fromthe Entity List, while conducting anin-depth investigation based out ofthe company’s headquarters inShenzhen, China. Innumerable legal,cultural, and language differenceswere overcome so that ZTE couldcooperate fully with the investigationafter ZTE had initially misled the USgovernment about shipments of US-origin goods to Iran and to NorthKorea.

Clifford Chance secured asettlement for ZTE despite hostilityand mistrust towards a Chinesecompany that had misled the USgovernment. Ultimately, ZTE agreedto plead guilty to obstruction ofjustice and providing falsestatements, as well as to exportcontrols and sanctions violations. Thesettlement with the US Department of

Justice (‘DOJ’), the US Department ofCommerce Bureau of Industry andSecurity (‘BIS’), and the USDepartment of the Treasury Office ofForeign Assets Control (‘OFAC’),concluded a five-year investigationinto allegations that ZTE had violatedUS export controls and sanctions laws.

As ZTE Corp. moves forward, it isfocused on implementing a robustand best-in-class export complianceprogramme developed by CliffordChance.

The Clifford Chance team was ledby Wendy Wysong (Washington, DCand Hong Kong) and included teammembers from the firm’s Hong Kong,DC, New York, Singapore, Beijing,and Shanghai offices.

Runner-Up: Jacobson BurtonKelley

For a small outfit, DC/New York firmJacobson Burton Kelley enjoys amassive reputation. The firm hasthree partners – Doug Jacobson,Michael Burton and Glen Kelley –who each have substantial experiencein working with US and non-UScompanies on all aspects arising outof dual-use and defence-relatedexport controls. Among other

instructions, the firm is providing allUS export controls and economicsanctions compliance advice relatingto a large potential project in Iran, tobuild and operate infrastructurefacilities with an Iranian joint venturepartner. Advice covers, among otherareas, compliance with US export andre-export controls potentiallyapplicable to articles and technologieslocated outside the United States to beexported to Iran as a part of theproject, and advice on:

l whether such items are subject tothe the EAR, and if so how they areclassified under the EAR

l deemed export issues for proposedtechnology transfers to non-USpersons as part of the project

l the overall structure for theinvestment and the proposedbusiness activities in Iran

l the proposed project partners,banks providing financing andother parties involved in theproject.

l general advice regarding thedynamic US and EU regulatorylandscape relating to Iran, and thepotential for changes in relevantexport controls and sanctions.

In a word: awesome!

Export Controls Law Firm of the year, U.S.A.

Wendy Wysong of Clifford Chance

The firm secured the first ever ‘Temporary

General License’, enabling its client ZTE to stay

in business during the pendency of a multi-

agency export control investigation.



Highly commended

Akin Gump has one of the world’slargest export controls practices, withteam members based in offices in theUS, Asia, the Middle East and Europe.

In the past year, the firm has beensuccessful in recruiting high-profilelawyers to its partnership – KevinWolf, as mentioned above, and JasperHelder from Baker McKenzie inEurope. Other highly regarded teammembers include Thomas J.McCarthy, Wynn H. Segall andJonathan C. Poling in DC, andTatman R. Savio in Hong Kong.

Among the year’s instructions, theteam helped a company obtain afavourable EAR classification rulingon a novel information securityproduct. The team worked with thecompany to develop accurate andcomplete information and thendrafted and submitted the class -ification request. The ruling allowedthe company to execute its businessplan by obtaining certainty onlicensing requirements and reducingburdens through the use of exceptionswhere appropriate and possible.

Winner in this category in 2015and 2016, Steptoe prides itself onpractical advice that takes intoaccount business needs; quickresponse time; expertise throughoutthe ranks of associates, counsel, andpartners; deep expertise across

multiple regulatory disciplines; andits ability to handle US and non-USexport control regimes.

High-profile instructions haveincluded advising the Coalition forResponsible Cybersecurity, whichrepresents a broad cross section ofUS- and EU-based cybersecuritycompanies, including Symantec,Philips, Microsoft, Ionic Security,FireEye, and Raytheon. In 2015-2016,Steptoe was at the forefront of theCoalition’s efforts to educate US andnon-US policymakers on theperceived negative effects of theWassenaar Arrangement’s rules onintrusion software, includingcomments on the proposed rule,presentations at numerous BISTechnical Advisory Committeemeetings, and congressional outreach,resulting in the US government’sagreement to seek renegotiation of therule with other WassenaarArrangement members in 2016, andagain in 2017. Beginning in 2016, thiseffort expanded to include abroadened focus on the EU’sproposed changes to its dual-useregulations as those relate to cyber-related activity, with Steptoe’s officesin London and Brussels fullyintegrated into this effort.

Hogan Lovells has a strength indepth in its export controls practicethat few firms can match. With highlyregarded practitioners in DC and

Brussels, the firm is ‘at the forefrontof virtually all cutting-edge exportcontrol issues’.

This is a truly internationalpractice, as a glimpse at just two of along list of instructions from the pastyear illustrates.

l The firm assisted CorporacionNacional de Telecomunicaciones(‘CNT’), the largest Ecuadoriantelecommunications servicesprovider, in seeking removal fromthe BIS Entity List. Under therestrictions imposed by BIS,exports to CNT of certaintelecommunications infrastructurecomponents and equipmentrequire an export licence (whichwould otherwise not be the case).The firm is advising the companyin the review of transactions andenhancing CNT’s trade complianceprogramme, and working with theclient to seek its removal from thelist and support the approval of USgovernment licences.

l The firm represented a major USdefence company in a range ofmatters, such as noveljurisdictional issues related tocommercial communicationssatellites and their components,and the relationship between tradecontrols laws and requiredreporting to the SEC and othergovernment agencies.

Winner: HFW

HFW (née Holman Fenwick [&]Willan) has a worldwide focus actingfor companies in the commodities,mining, energy and resources,shipping, aviation and insurancesectors, including providing themwith export controls expertise.Anthony Woolich, global head of thefirm’s Competition and Regulationgroup, and Daniel Martin, are keycontacts based in the London office.In the past year, two lawyers withstrong export control and sanctionspractices, Pauline Arroyo in Paris andSarah Hunt in Geneva, were electedto the partnership and the group alsoincludes six associates across theParis, Geneva and London offices.

The firm displays laudable

initiative in servicing its clients, as itshowed when acting for a majorEuropean shipowner reviewingrequests from its charterer to carrynumerous military and dual-usecargoes to a variety of destinations.Having originally been asked toreview individual requests on an adhoc basis (checking cargoes, licencesand associated documents), the firm

set about devising a streamlinedprocess which clients couldthemselves follow, in order to reducethe costs of compliance, and speed upthe process. And working with amajor provider of IT solutions to theshipping industry on a product whichwill allow controlled cargoes to beidentified and managed moreproactively within the transport

Export Controls Law Firm of the year, Europe

Anthony Woolich and

Daniel Martin of HFW



process, the firm has helped clientsreduce delays and costs.

Other instructions have seen thefirm assist a multinational on EU/USand Canadian export controlsimpacting a proposed supply ofdrilling equipment to Iran. The teamadvised on the position under EU lawand coordinated the advice on the USand Canadian aspects, includingengaging a Canadian classificationexpert. Elements included advice onstructuring trade flows to ensurecompliance with export controlrequirements, including US deemedexport rules.

Runner-Up: Baker McKenzie

Swapping places on the podium, lastyear’s winner in this category is thisyear’s runner-up. Baker McKenzie is agiant in export controls advice. Withtrade lawyers in Amsterdam,Frankfurt, London, Brussels, Zürich,Barcelona, Stockholm, Rome,Moscow, Paris, Warsaw and Budapest(and more offices than we have spacefor here), the depth of its Europeanpresence is unmatchable. Many of thefirm’s non-US attorneys specialisingin export controls in theirjurisdictions are well-grounded in USexport controls, particularly withrespect to their extraterritorialapplication.

In the past year, the firm

l Provided trade complianceassistance to one of the world’sleading military defence companiesbased on a global agreement tosupport its business around theworld. Advice includes bothmilitary and dual-use advice andspans trade compliance, brokeringand sanctions. The work iscoordinated by the Stockholmoffice but involves practitioners inmore than 20 jurisdictions.

l Advised a leading Germanautomotive supplier on theimplementation of a new globalcompliance programme for theGerman headquarters and allgroup companies worldwide; theclient instructed the firm toidentify export controlrequirements in those countrieswhere it maintains groupcompanies.

l Advised a leader in the globalpackaging solutions sector as to

potential issues under the Turkishtrade sanctions and export controlsregarding Syria.

l Advised a technology giant on adiverse range of issues relating to'cyber' exports, imports andsanctions across the EMEA regionand globally.

Highly commended

Pillsbury’s international tradepractice in Europe is based out of thefirm’s London office. The firm assistsclients in the preparation of licenceapplications and in the use of generallicences and exemptions, incompliance planning, training, inexport audits, on voluntarydisclosures of export controlviolations, internal investigations,negotiating settlements, and defendscompanies in both administrativeenforcement proceedings andcriminal prosecutions.

A rich and varied workbook hasseen the firm

l Represent a global technology andonline services company in twoseparate UK government exportaudits, resulting in no negativefindings on both occasions.

l Work closely with in-house counselon updates to business-wide ITAR,EAR, and European export controlprocedures for one of the world’slargest defence companies.

l Provide ongoing advice as outsideexport counsel to a Fortune 100global technology and social mediacompany on EU export controlissues.

l Advise a Japanese consortium onEU and Norwegian software andequipment export controls for amajor Russian energy project.

l Advise an Asian company on EUexport controls applying to use ofsoftware for an Iranian energyfield.

Baker Botts has deep export controlexpertise in both its London andBrussels offices, with the two officesworking closely together on a varietyof mandates. The team is led by GeorgBerrisch in Belgium and ChrisCaulfield in the UK.

The firm acted for a major globalhelicopter operator in a particularlysensitive licensing matter – the clienthad already made one self-disclosure

to the UK authorities a few yearsearlier in respect of unlicensedexports. The firm was engaged toassist in determining whetherunauthorised exports had been made(they had), investigate the extent ofthose unauthorised exports, andadvise on the best tactics with the UKauthorities in respect of making avoluntary disclosure. The firmassisted the in-house legal team indrafting the voluntary disclosure andin achieving a successful resolutionfor the client vis-a-vis the UKauthorities.

In another instruction, the firmadvised one of the world’s largestaircraft leasing companies in respectof a review of its export controlprocesses, helping it to streamlineand consolidate existing processesand providing in-house training inboth Ireland and the US tocommercial and legal teams.

Hogan Lovells’ extensive networkof offices in Brussels, Amsterdam,London, Moscow, Munich, Paris andRome, lets it address export controlissues that span EU Member Statesand beyond. Lourdes Catrain inBrussels is a much-liked and highlyregarded practitioner.

A glimpse at the past year showsthe capabilities of the team in Europe:

l Advised a US multinationaltechnology and social mediacompany on the export control andimport aspects of their productsinto the EU from the US andChina.

l Acted for major US/UK defencecompany, Meggitt, in itsacquisition of the globalcomposites business of Cobhamplc. Conducted a due diligence onUK, EU, and US trade controls andeconomic sanctions of Cobham plc.

l Advised a leading Europeanautomotive supplier on exportcontrol matters, includingassessing the exposure to EUexport control laws of newproducts. Assisted the company instrengthening its exportcompliance policies.

l Assisted a leading life sciencescompany with export controlmatters, from a UK affiliate to aRussian joint venture.

l Advised a leading Spanishcompany developing acommunications platform in Iran.


Winner: Accenture

Accenture’s Global Trade Complianceteam (‘GTCT’) looks to the future. Notcontent with its runner-up position inthis award last year, the team haspushed forward in its ambition tobecome ‘one of the most effective in-house compliance teams in the world’and during the past 12 months setabout putting together a four-pointplan to take its game to the next level(see below).

Led by managing director of GlobalTrade Compliance, John Pisa-Relli, theteam regularly receives plaudits fromthe marketplace: ‘terrific’; ‘combinesdeep knowledge of the US and EUregulations with a very practicalapproach to export controlcompliance’; ‘takes a plain English,common-sense approach to tradecompliance’; ‘highly innovative incoming up with new ways tocommunicate a complex system withintheir organisation’.

Comprising seven trade complianceprofessionals – four lawyers whosupport specific geographic areas, aglobal director of asset classificationand trade logistics, and twoprogramme managers who oversee keycompliance functions, such as deniedparty screening and who provide vitaladministrative support – the teamsupports a 400,000-employee globalgiant. The team is committed todiversity, inclusiveness, and corporatecitizenship – 60% of the GTCT isfemale and its ranks span ethnic andcultural backgrounds.

Pisa-Relli is keen to explain theefforts the team is taking to improvefurther: ‘Accenture completed a riskassessment in 2016 in which expertoutside counsel concluded that itstrade compliance programme is“effective” and “well-tailored” to thecompany’s risk profile today.Nevertheless, Accenture leadershipchallenged the team to find ways toanticipate international trade controltrends and the next wave of risks toremain fit for purpose tomorrow.Based on the risk assessment findings,the GTCT presented a four-point planto Accenture leadership to enhance theeffectiveness of its trade complianceprogram: SEAL (Simplify, Educate,Automate, and Leverage).

‘Simplify: A revamped tradecompliance policy replaced two lengthypolicies with a single short and clearmission statement. Instead of densetechnical language and citations tostatutes and regulations, the currentpolicy explains international tradecontrols to the vast Accentureworkforce, using the simple concept ofWHERE, WHO and WHAT. Tradecontrols regulate WHERE we dobusiness, WHO we are permitted to dobusiness with, and WHAT industriesand technologies are subject toenhanced controls. Employee responseto this simplified policy wasoverwhelmingly positive andempowered an army of issue spottersto raise matters that require specialhandling to the deep subject matterexperts on the GTCT.

‘Educate: In 2017 the GTCTstreamlined the computer-based tradecompliance training course that asignificant portion of its 400,000person workforce is required to takeand increased its use of internal socialmedia platforms to increase awarenessof international trade controls in amore interactive and agile manner. Inaddition to being able to communicatechanges in the law to key businessstakeholders immediately, the GTCTuses these platforms to demystify tradecompliance and make it interesting tothe broader Accenture community.

‘Automate: The GTCT has launchedan ambitious effort to use theinnovative technologies that Accentureis developing for its clients to drive itsown compliance. For example, theGTCT is designing ways to automatescreening for trade compliance issuesduring the opportunity intake andmanagement process. Our ambition isto automate wherever possible, to freeup the subject matter experts and their

support teams to handle the complexmatters that require humanintervention and decision-making.

‘Leverage: Though managed by asmall team, trade compliance is veryvisible to Accenture’s vast workforce.To extend its reach and amplify itsvoice, the GTCT works closely with keystakeholders in the company’s legaldepartment, who serve as forcemultipliers. Emerging initiativesinclude fostering a closer collaborationwith intellectual property lawyers andR&D labs to ensure that Accenture isable to classify its technologies forexport controls early in their lifecycle.’

WorldECR applauds the team forits forward-thinking approach and forits pursuit of excellence.

Runner-Up: 3M TradeCompliance

3M Global Trade Compliance isresponsible for the operationalmanagement of import and exportcompliance of 3M Company and all ofits subsidiaries around the world. Itoversees annual cross-border trade ofover $12.6 billion, which includes tradein over 1,500 export-controlledcommodities.

The core corporate exportcompliance team consists of a GlobalManager and seven export controlsspecialists and analysts, located at 3Mcorporate headquarters in St. Paul,Minnesota, United States. The GlobalManager responsible for 3M exportcompliance is Pierre J. LaMere, a 3Memployee of more than 27 years.

In 2016 and 2017, the 3M teamembarked on a bold initiative to deploya single-instance ERP system based onSAP throughout its global operationsand to standardise and modernise its

Export Controls Compliance team of the year, U.S.A.


John Pisa-Relli, Accenture

‘The multinational group led by Pisa-Relli

is knowledgeable, practical, and nimble

enough to address the most difficult trade

controls challenges,’ reports one market

peer.



business processes. Working closelywith 3M’s IT specialists, this businesstransformation team set aboutensuring that 3M’s export compliance-related controls that were built andcustomised in legacy IT systems overmany years were not only transferredto a new platform, but enhanced andmade capable of taking advantage oftechnological advantages of the newERP system.

The open design of the ERP system,which is based on servers located in theUnited States and is intended toprovide global transparency tomanufacturing data, presented 3M’steam with unique and unprecedentedchallenges in securing access to 3Mexport-controlled technical data.Restrictions on the collection ofpersonal data based on the data privacylaws of certain countries furthercomplicated the task of ensuringappropriate access control restrictionsto controlled technical data. A3Mcolleague from outside the teamcommented: ‘The 3M TradeCompliance team has risen to theoccasion, inventing and implementinga new IT access control strategy thatappropriately balances risks ofunauthorised access to export-controlled data against data privacyconcerns.’

Other achievements for the team inthe past year have included

l Successful engagement with the USDepartment of Commerce toobtain an advisory opinion onwhether intra-company transfersof controlled technical datacovered by end-to-end encryptionconstitute exports giving rise tolicensing requirements;

l Due diligence and management ofexport compliance risks in severalsignificant acquisition anddivestiture projects; and

l Effective regular engagement withand training of division technologycontrol managers, who perform theroles of export control extensionofficers in 3M’s 26 businessdivisions.

The contribution of the team to thecompany’s success is recognisedoutside the department. As a memberof another department notes: ‘Thecontributions of 3M’s export controlscompliance team have also been animportant enabler of 3M business.Historically, the team has been able to

efficiently support business bynavigating numerous complex areasof export control and embargo andsanctions compliance with a relativelysmall commitment of resources and inthe context of ever-changing businessand foreign policy environments.Today, in addition to their traditionalbusiness-enabler role, the exportcontrols compliance team is enablingthe company’s process of businesstransformation, by obtaining criticalgovernment authorisations andguidance, and finding innovativesolutions to ensure compliance in thesingle-instance ERP environment.’

Highly commended

Weatherford is one of the world'slargest oil and natural gas servicecompanies. The company providesproducts and services for drilling,evaluation, completion, productionand intervention of oil and natural gaswells, along with pipeline constructionand commissioning. Headquartered inSwitzerland, Weatherford operates inmore than 100 countries across theglobe and employs more than 35,000people.

In 2013, the company made apayment of $253 million to settlesanctions and anticorruption violationallegations. Four years on, thecompany is widely seen to have turnedthings around and now enjoys anexcellent reputation for itscommitment to trade compliance.Natalia Shehadeh, vice president andchief compliance officer, leads theTrade Compliance Program Teamwhich also includes Melissa Bohannonand Randi Heuser (both Houston),Patrick Crawford (Zurich), and SergioPenna (Rio de Janeiro).

The team sits within Weatherford’scompliance function, providingsupport to all departments involved in

international business in 80+countries. These would include thefollowing and more:

l classification data managementand denied party screening withintrade automation

l drafting, issuing and training onformal trade guidance and policies

l creating and auditing tradeprocedures

l providing oversight to all trade-related government enquiries

l and mitigating trade risk

The team’s focus is very much aglobal one, with a trade compliancemanager/counsel in each region inwhich the company operates,supported by members in Houston andSwitzerland. All of the regional tradecompliance managers and counsel ‘arefluent in import, exports, exportcontrols, antiboycott and sanctionscompliance as it relates to theirgeographic responsibilities. We viewthis as delivering the highest quality,real-time service to our business,rather than cultivating siloed experts inimports versus export controls.’

The importance of a goodunderstanding of the markets andcultures that the business operates inunderpins the staffing in complianceand team members have ‘expertisespecific to the regions they support,while we also look for opportunities forcareer development and expose ourteam to cross-regional training,development and careeropportunities.’

With a commitment to goodtraining and investment in systems –’We have implemented somebest-in-class automation tools thatraise the service quality bar of oursupport to the business and greatlyreduce our regulatory’ – the problemsof the past have been put well andtruly behind them.

The team at 3M Global Trade Compliance; Pierre LaMere is on the far right.



Winner: Celestica, Logistics& Trade Compliance team

‘The WorldECR Awards recogniseoutstanding work, vision, bestpractice, commercial benefit to thecompany, and contribution tointernational security,of organisations and individualsworking in the fields of export controland sanctions compliance and non-proliferation.’ Whilst the raison d’etre

of these awards may seem sensibleand straightforward, manyorganisations still struggle tounderstand that good tradecompliance practice need not inhibitsales and exports – instead, it canpositively boost productivity andprofits. The winner of this awarddecided a year ago that a significantinvestment in the company’s exportcompliance effort could only be a win-win. They have been proven right.

Headquartered in Toronto, Canada,Celestica employs more than 25,000people across 25 sites in the Americas,Europe and Asia. The companyprovides design, engineering,electronics manufacturing and supplychain management services, andglobally is involved in over 11,000export transactions each week.

The Logistics & Trade Complianceteam is home to 19 people supportingthe commercial activities of thecompany, mainly based in offices inToronto, Hong Kong and the UK – astructure which, according to DominicCarabine, Senior Director GlobalLogistics & Trade Compliance, ensuresthat the business receives 24-7 exportcompliance advice. The company iscommitted to compliance with traderegulations around the world and thatby its nature puts pressure on theeffective operations of the complianceteam. To ensure even greater successin its trade compliance efforts, lastyear Carabine’s team embarked on anautomation project which wouldensure that each and every one of the11,000 weekly exports was compliant.

‘The successful export of theseshipments, and their compliance withlocal legislation,’ says Carabine, ‘isimperative to the responsiveness ofour global supply chain. Previously,

our trade compliance processes weremanual, and differed from site to site.These varying processes put Celesticaat risk for cash penalties as well aslimiting the company fromsuccessfully entering into key marketswith high control requirements.’

Working with an externalconsultant, the team set out toautomate the company’s compliancewith international trade laws andregulations governing the export ofcross-border transactions byintroducing the SAP global tradeservices (‘GTS’) module into itsexisting SAP framework in 23 sitesaround the world.

From the start, the Celesticaproject team was firmly focused onthe international nature of thebusiness and this informed theirdecision as how best to approach thechallenge. As Carabine says, ‘WhileCelestica is a North American-basedcompany, we chose to engage with apartner that had a global softwaresolution that allowed Celestica tomeet the export requirements of allthe countries we currently operate in.

‘In addition to the European exportlicensing requirements, Celestica wassubject to the Malaysian StrategicTrade Act and developed acompliance programme within GTS tocomply with Malaysia’s exportrequirements. We have alsosuccessfully implemented the importand export controls for Hong Kongwith GTS. We are currently indiscussions with our partner aboutthe proposed export regimeimplementation of Thailand.’

The new system enables:

l Automation of sanctioned party

lists screening for allin- and outboundshipmentsl Automation oflicence management l Mass HSclassification upload l Audit trails for bothinternal and externalsourcesl Automation andstandardisation oftransactional deniedparty screening and

export licence determinations

According to Carabine, a furtherbenefit of the process was to remindother areas of the company of theimportance of compliance. ‘Theimplementation of GTS drovesignificant change within Celestica,’he says, ‘directly or indirectlyimpacting employees on thecustomer-facing side as well as inSCM, Operations, Logistics and TradeCompliance Teams. GTS ensures allinternational shipments are screenedand that the correct trade licences arein place. If the correct licences are notin place, or a party is blocked by thesanctioned party screening, theshipment is blocked. The compliancerisk is reviewed and where possibleresolved to allow the shipment toproceed.’

Throughout the project, the team‘focused on aligning all the levelswithin the company, including theexecutive team through regularcommunication.’

Carabine is pleased with theimpact of the new system: ‘As a resultof the GTS implementation, we haveincreased our speed to adopt exportcompliance regulatory changes whilecontinuing to ensure the highestlevels of trade compliance. Thisallows Celestica to continue toflourish within its core markets aswell as in growth markets, such asaerospace and defence which havestrict export compliancerequirements. We now have 100% ofour SAP export transactions screenedand the applicable licencedeterminations automaticallyassigned. In 2016, Celestica’s SAP-

Export Controls Compliance team of the year,

Rest of the World



Winner: Meggitt

‘Meggitt is committed to maintainingfull compliance with the laws andregulations governing trade controls inall jurisdictions in which it operates.’Charged with delivering on this is thewinner of this year’s award for ExportControls Compliance team (Europe),Trade Compliance at Meggitt.

A multi-million pound business, thecompany has five divisions – includinga number of market leaders: AircraftBraking Systems, Control Systems,Polymers & Composites, SensingSystems and Equipment Group –mainly supporting defence andaerospace clients, such as Airbus,Boeing, BAE Systems and the USgovernment.

Natasha Allen, Head of TradeCompliance, Europe & Asia, leads theteam whose mission statement is ‘Toserve the Meggitt business communityby providing support, guidance anddirection in the application ofappropriate trade complianceregulations while facilitating thelegitimate business of the company andits partners.’ A more succinct brief is to‘ensure end-to-end compliance incoherence with national, EU and USlaws and regulations’.

The company is committed to tradecompliance. ‘In 2003 Meggittimplemented the import compliancesection of our trade complianceprogramme which complements the10+ years spent on implementing theexport compliance aspects,’ notesAllen. ‘We believe that TradeCompliance is now “institutionalised”within Meggitt.’

Undoubtedly, this is why the teamreceives positive comment: ‘Those I’ve

met from Meggitt have impressed megreatly,’ says one consultant. ‘Theyclearly know their stuff and seem to goabout their business in a no-nonsenseand reassuring manner.’

Trade Compliance has roughly 50people within Europe and Asia, full-and part-time, seven at the corporatelevel and the remainder site-based.Allen explains: ‘Corporate personnelare responsible for the implementationof trade compliance business systems,internal audit (trade compliance) andimport/export compliance to ensurecontinued implementation of the in-house trade compliance programme inline with corporate objectives and bestpractice, while sites are responsible forthe daily activities relating to allaspects of import, export and tradecompliance.’

The team supports Meggitbusinesses in the UK, France, Spain,Germany, the Netherlands, Denmark,Switzerland, Vietnam, Singapore,China and Australia and offers full end-to-end compliance processes for eachbusiness, in line with the company’sglobal compliance policy andprocedures.

Allen is an advocate for strongcompliance within the business: ‘Our

greatest success ,’ she says, ‘has beenchanging the perception of ourfunction within the business and ourcustomers. With the work of ourdedicated and fully trained team, weare now seen as a facilitator ofbusiness, where each functionrecognises the need to work with TradeCompliance to achieve the desiredgoals, being proactive rather thanreactive. This has helped the businessto be both more commercially andfinancially responsible.’ Three regionalcouncil meetings a year are the timeand place to invite other functions tointeract with Trade Compliance.

Having got the rest of the companyon board, there is no standing still.‘The Trade Compliance functioncontinues to evolve to meet the ever-changing demands of the complexregulatory and challenging businessenvironment,’ says Allen. The companyhas invested in SAP Global TradeServices (SAP GTS) at 24 facilitiesacross four countries. The systemprovides an automated solution tomitigate the risk of transacting directlyand/or indirectly with entitiesincluding end-users who are debarred,subject to sanctions or located in anembargoed country.

Export Controls Compliance team of the year, Europe

Natasha Allen, Meggitt

The Meggitt team seeks to ‘ensure end-to-end

compliance in coherence with national, EU and

US laws and regulations’.

GTS completed sanctioned partylisting reviews for over 400,000purchase orders and over 230,000sales orders. This advanced licensingstrategy allows Celestica todifferentiate itself in the marketsegments in which we operate.

‘In addition, it further enhancesCelestica’s overall supply chainsecurity programme in that it ensurescontrolled parts are only moved byvalidated and approved carriers.

Celestica has incorporated best-in-class security over the years to attaincertification in the supply chainsecurity programmes of the EU,Canada, Mexico, United States, China,and Thailand.

‘By incorporating GTS into ourorder management system andtherefore ensuring compliance to theexport regulations of countries weoperate in, we are confident that weare dealing with known parties that

are approved to receive and handlecontrolled goods. Coupling this withCelestica’s participation in securityprogrammes such as C-TPAT, PIP andAEO, we are further safeguarding thecontrolled product by shipping thegoods with partners that havedemonstrated similar commitment tooverall security.’

WorldECR congratulates Carabineand his team on what is clearly a goodjob well done.

www.worldecr.com

News and alerts News and alerts

The publishers of WorldECR are pleased to announce the

publication of The Export Compliance Manager’sHandbook, a new guide designed to act as both an

introduction to some of the key areas of export control

compliance practice and also as a helping hand in dealing

with typical challenges.

The Handbook (264 pages) falls into

26 chapters plus Foreword and

Glossary, and includes insight from a

number of popular and highly

respected WorldECR regular

contributors.

Writing in the Foreword to the

Handbook, WorldECR editor, Tom

Blass, notes: ‘Our mission in

commissioning the chapters that

constitute this book has been to

provide a common-sense overview

of the key issues pertinent to a

complex subject.

‘In its conception, we saw it as

a helpmate for the export

controls compliance practition -

er, whether a long-in-the-tooth

veteran who remembers the

CoCOM (‘Coordinating

Committee for Multilateral

Export Controls’) but needs a

refresher on a fast-changing

area of law, or a newcomer,

born, plausibly, even after the

fall of the Berlin Wall, and excited to be

entering an area of practice which reflects the great seismic

shifts in political geography that continue to enliven, though

occasionally imperil, our lives.’

Content

The chapters and contributing authors are:

l The multilateral export control regimes: an introduction

by Laura Rockwood, Executive Director of the Vienna

Center for Disarmament and Non‑Proliferation

l The United States Export Control Reform Initiative by

Bruce H. Leeds and Jennifer Horvath, Braumiller Law

Group

l The U.S. Export Administration Regulations (‘EAR’): an

introduction by Olga Torres, Torres Law, PLLC

l Navigating the ITAR by Olga Torres, Torres Law, PLLC

l Dual-use export controls in the European Union by

John Grayston, Grayston & Company

l Export controls beyond the United States and European

Union by Jay Nash, SECURUS Trade

l Export controls adopted as trade sanctions measures by

Glen Kelley, Jacobson Burton Kelley PLLC

l U.S. antiboycott laws: overview and compliance

strategies by Kim Strosnider and Christine Minarich,

Covington & Burling LLP and Raytheon Company

l Implementing an Internal Compliance Programme

(‘ICP’) by Stacey Winters, Deloitte

l A step-by-step overview of U.S. commodity jurisdiction

by Olga Torres and Matt Fogarty, Torres Law, PLLC

l Developing and implementing a restricted party

screening programme by Kevin J. Cuddy, GE Corporate

l Global Trade Automation: an introduction by Pablo

LeCour, Deloitte

l Record-keeping and export control compliance: what to,

how to, and why you must by Lila Rose, PolyOne

l Re-exportation Part 1: The EAR

by Kevin DiBartolo, Latham &

Watkins

l Re-exportation Part 2: ITAR

and OFAC by Kevin DiBartolo,

Latham & Watkins

l Key elements of technology

transfers under U.S. export controls by

Michael Burton and Glen Kelley,

Jacobson Burton Kelley PLLC

l Export controls and sanctions in the

cloud: a U.S. perspective by Joseph

Schoorl, Hughes Hubbard & Reed

l Export controls and cryptographic

items by Richard Tauwhare, Dechert llp

l Intra-company transfers by Ajay

Kuntamukkala, Lourdes Catrain, Roy Liu

and Christopher Lock, Hogan Lovells

l Compliance for exporters and freight-

forwarders: a shared approach by Jamie

Joiner and Ashley Moore, Joiner Law Firm

PLLC

l U.S./EU defence brokering: an

introduction by Jack Hayes, Steptoe &

Johnson

l U.S. export controls and sanctions risks in the

manufacturing supply chain by Timothy P. O’Toole and

Abigail E. Cotterill, Miller & Chevalier Chartered

l Recognising and responding to ‘red flags’ by Robert

Shaw, James Martin Center for Nonproliferation

Studies, Middlebury Institute of International Studies

at Monterey

l Anatomy of an export control investigation by Ryan

Fayhee and Alexandre Lamy, Baker McKenzie

l Disclosures in the United States – when to, what to

consider, and how to do it by Alexandra Baj, Steptoe &

Johnson

l Disclosure: a global approach by Tristan Grimmer and

Daniel Lund, Baker McKenzie

New from WorldECR – The Export Compliance Manager’s Handbook

��

��

How to order

The Export Compliance Manager’s Handbook will be

available from mid-May 2017 directly from WorldECR.

Copies cost £45 (plus postage and packing). For further

information and to order your copy, please email

[email protected] with your order requirements.

Discounts for bulk orders are available.



Winner: HFW

Capping off a very good year for itstrade practice WorldECR-wise, HFW(Holman Fenwick Willan as was) has‘done the double’ and is both ourSanctions Law Firm (Europe) of theyear and Export Controls Law Firm(Europe) of the year. Congratulationsto the team, steered by AnthonyWoolich and Daniel Martin inLondon.

The firm’s focus is on commodities,construction, energy, shipping,aviation and insurance, with lawyersin Europe, the Middle East, the FarEast and Australia advising onsanctions issues impacting clients inthese sectors. It offers ‘innovative,creative and progressive advice’ in thesanctions area and ‘a particular focuson utilising technology and otherstreamlining processes as clients seekto meet the competing demands ofensuring compliance with complexinternational regulations, whilstsatisfying the requirements of theircustomers for prompt and accuratedecision-making.’

The firm’s creative approach wason view in a recent instruction whichsaw it carry out sanctions checks forshipowners and operators inconnection with particular voyages toand from ports in sanctionedcountries: ‘The service is provided onthe basis of a fixed fee, so that theclients can factor in the “cost ofcompliance” when deciding whetherto enter into negotiations for aparticular voyage,’ it reports.

Other instructions includedadvising a bank on proposed changesto the rules of a commoditiesexchange with reference to sanctions– difficulties and delays were arisingfrom the exchange’s failure to ensurecompliance with sanctions by partiesusing the exchange. ‘This was a rareopportunity to influence thedevelopment of the exchange’s rulesto recognise the significance ofsanctions for international trade.’

The sanctions team was also busysupporting the corporate effort,carrying out due diligence on a multi-million pound acquisition of abusiness in the oil and gas sector, soas to determine whether the target

company had engaged in anytransactions with countries insanctioned countries, the impact ofthose transactions, and suitablewarranties in the share purchaseagreement.

Finally, the firm’s energy sectorexpertise was brought to bear whenadvising a multinational on theproposed supply of liquefied naturalgas (‘LNG’) in Cuba for an integratedLNG to power project being procuredby the Cuban government. Theproject, says the firm, ‘is an exampleof potential opportunities for Westerncompanies in Cuba using leading-edgetechnology’.

Runner-Up: Clyde & Co

The sanctions group at Clyde & Coconsists of more than 25 lawyersspread across the firm’s globalnetwork of 47 offices in six continents.The group wins mandates to advise onhigh-profile and sensitive sanctionsmatters due to its ‘unrivalled expertisein this area of law and its in-depthknowledge of its core sectors’ ofinsurance, trade and commodities,energy, transport and infrastructure.Initiatives such as an Iran desk, set upin Autumn 2015 across its MENAoffices, have reportedly provenpopular with clients.

In the insurance sector, the groupadvised an international carmanufacturer as to the reportingobligations arising under UKsanctions and counter-terrorismlegislation in respect of insurancecover sold as a package with itsvehicles. In the construction sector,the group advised investors in twomulti-million-dollar portdevelopments in Iran on the sanctionsimplications of their investments.

In other areas, the firm advised aneast Asian shipping company on theimplications of performing acontainer liner trade with Iran;advised a European mobile virtualnetwork operator on the sanctionsimplications of its entry into Iran; andadvised a ship-owner on the sanctionsimplications of a charterparty for thecarriage of goods to and from Iranand Sudan.

Highly regarded team membersinclude John Whittaker, Nigel Brookand Chris Hill in London, and PatrickMurphy in Dubai.

Highly commended

Baker McKenzie’s advice wasinstrumental to the re-establishmentof two major European airlines’ flightsto Tehran. Lawyers from the London,Amsterdam, Washington, and PaloAlto offices worked with multi-disciplinary teams within the clients’organisations, including generalaviation, engineering, logistics,finance, and sales, all the way up tothe C-suite. The lawyers had tocarefully map out the operationalneeds and challenges going into a newmarket, and be forward-thinking toanticipate and resolve the associatedlegal and regulatory hurdles in orderto make the market entrycommercially and financially viable. Asignificant degree of policy work wasalso involved in dealing withregulators and policy makers on bothsides of the Atlantic and getting themto talk to each other at a diplomaticlevel.

Hogan Lovells provided one ofthe world’s leading diversified miningand smelting groups ongoingoperational legal advice on economicsanctions, including sensitivequestions relating to operations andfinancials. The firm assisted thecompany’s treasury department in thenegotiation of a credit line with an EUsubsidiary of a Russian state-ownedbank subject to EU financialsanctions. Other instructions for thefirm included

l Assisting an international oil andgas Europe-headquarteredcompany in connection with the

Sanctions Law Firm of the year, Europe



Winner: Akin Gump

In what came to be one of the mosttalked about sanctions matters in theUS in the last year, Akin Gumphelped facilitate an historicpartnership between the US RoswellPark Cancer Institute and the Cuba-based Center of MolecularImmunology (‘CIM’), successfullysecuring a first-of-its-kind USgovernment licence that authorises acommercial joint venture between aUS company and a Cuban state-owned organisation. This aim of thejoint venture is to push forwardbiotech developments and help bringa groundbreaking Cuban lung cancervaccine and other unique cancertreatments developed in Cuba to USpatients.

Akin Gump helped Roswell Parkobtain the historic Office of ForeignAsset Control (‘OFAC’) licence,approved by the US Department ofthe Treasury, authorising the instituteto enter into a joint business venturewith the CIM – this marked the firsttime OFAC has authorised a US-Cuban joint venture. As a result,Roswell Park is now partnering withCIM to develop the lung cancertreatment vaccine CIMAvax-EGF®.In addition, the firm also assistedRoswell Park to obtain related OFAClicences to conduct clinical trials incollaboration with CIM as well asexport licences for the export to CIM

of equipment and technology essentialto the joint medical research efforts ofthe two institutions.

Also, with assistance from AkinGump, Roswell Park receivedauthorisation from the US Food andDrug Administration (‘FDA’) to beginoffering CIMAvax to US patientsthrough a clinical trial, making theNational Cancer Institute-designatedcomprehensive cancer center the firstAmerican institution to receive FDApermission to sponsor testing of aCuban medical therapy in the UnitedStates.

The firm’s achievement issignificant: not only did thispartnership mark the first US-Cubanjoint venture since the Cubanrevolution, but it brought US citizensone step closer to potentially life-saving cancer treatments. The paththat led to the Akin Gump team’ssuccess included extensive meetings,advocacy and briefings of officials atOFAC, BIS, the NSC and more seniorWhite House officials, and a cross

section of Democratic and RepublicanMembers of Congress to gain supportfor the joint venture.

Roswell Park’s president and CEODr. Candace Johnson said of the firm:‘Our legal team has been incredible.We were going where no one has gonebefore. There are only a few law firmsin the country [with a practice]devoted to Cuban affairs, and AkinGump in Washington provided uswith incredible service.’

Runner-Up: Pillsbury

The sanctions and embargoes team atPillsbury boasts ’deep experienceadvising clients on compliance witheconomic sanctions and embargoesimposed by the US government underthe International EconomicEmergency Powers Act and theTrading with the Enemy Act,including sanctions regulationsadministered by the TreasuryDepartment’s Office of Foreign Assets

Sanctions Law Firm of the year, U.S.A.

Wynn Segal and Nnedinma Ifudu

Nweke of Akin Gump

Key members of the team advising

Roswell Park, which also included

Dallas Woodrum, Dan Feldman,

Steve Kho and Johann Strauss.

compatibility of the developmentof a large oilfield in Iran with EUand US sanctions. The companyhas US nationals in keymanagement positions and thefirm developed ‘a comprehensivecarve-out / Chinese wall whichwould allow the company todevelop the Iranian oil field withUS nexus’.

l Providing sanctions andcybersecurity advice to variousEuropean affiliates of a diversifiedglobal manufacturer.

l Assisting on trade-related M&Adue diligence involvingtransactions with sanctions-sensitive countries and conductingan anti-boycott internal

investigation involving bothGerman and US affiliates,assessing the merits of a voluntarydisclosure.

The team at Debevoise &Plimpton, well known for its adviceto financial instutions, also enjoyed abusy year advising on sanctionsmatters, which included:

l Providing transactional structuringadvice for Russian clientspotentially subject to EU sanctionsrestrictions.

l Assisting a client with identifyingand reporting historic sanctionsbreaches, and making licensingapplications to (at the time) the

newly formed Office of FinancialSanctions Implementation.

l Advice to fund sponsors on theimpact of EU and US sanctions onportfolio companies transactions.

l Advice to clients on issues relatedto US and EU persons serving onboards of directors.

l Advising Russian clients onengagements with Westerncounterparts in a sanctions-compliant manner.

l Providing ongoing advice tovarious major corporates, banks,insurers and other financialinstitutions regarding the ability toengage in Iranian, Russian andother transactions withoutviolating EU and US sanctions.


Control (OFAC) with respect tocountries such as Cuba, Iran, Sudan,Syria, Russia, Crimea (Ukraine) andNorth Korea, as well as terrorists,drug traffickers and other designatedentities.’ Highly regarded teammembers include partners NancyFischer and Christopher Wall andcounsel Aaron Hutman.

In a busy period, recentinstructions have included:

l Advising Sony PicturesEntertainment on economicsanctions matters (e.g., mattersinvolving Cuba, Iran, Russia, etc.).

l Advising Chevron on a wide rangeof international trade-relatedmatters, including economicsanctions, export controls(including technology transfers,encryption and deemed exports),anti-boycott, and customs matters.

l Advising a European bank inrelation to enhancements to USand EU sanctions and AMLprocedures for operations inmultiple jurisdictions, andproviding ongoing counsel supportfor US and EU sanctions matters.

l Advising a nuclear power companyactive in Turkey on US and EUsanctions relating to Russia.

Highly commended

In a fine example of how sanctions

can impact corporate activity,Skadden advised Nokia Corporationin connection with its acquisition ofAlcatel-Lucent and issues arising fromthat acquisition when it was foundthat a pair of minority shareholderswere designated under US Cubasanctions. Skadden lawyers succeededin getting the US Securities andExchange Commission (‘SEC’) toexclude the sanctioned persons fromthe tender offer, and also obtain alicence from OFAC to deal with thesanctioned persons in the context ofthe offer, allowing the deal to gothrough. (See WorldECR issue 54 forthe full story.)

Hogan Lovells assistedNissan/Infiniti in obtaining a licencefor the temporary export of an InfinitiQ60 car from the US to Cuba for usein news stories and video productionsby various media companies focusingon the design of Cuban-AmericanInfiniti executive design director,Alfonso Albaisa. Through extensiveanalysis of the Cuban Assets ControlRegulations, the firm ‘demonstratedthat the Commerce Department’sBureau of Industry and Security’s(‘BIS’) licensing of the temporaryexport was consistent with US foreignpolicy interests, including that theexport was integral to a journalisticproject that would promote contactwith the Cuban people, providevaluable cultural and educationalexchange between the people of the

United States and Cuba, and supportCuban civil society, as well as lead tothe creation of informationalmaterials. We crafted the legal andpolicy arguments, spoke several timeswith BIS to clarify the project, andultimately filed the licence application.We also were able to obtain the licencein approximately three weeks due to ashortened timeframe for completion ofthe project.’

Steptoe advised a Belarus-baseddesign institute serving the miningand chemical industries whose fundshad been ‘blocked’ by a US bank onthe ground that the client was ownedby a Specially Designated NationalBelarusian energy conglomerate,believed to be closely associated withBelarusian President Lukashenko. The‘blocking’ measure against the clientessentially cut it off from the USfinancial system and risked itsinternational business activitydenominated in US dollars (whichtypically clear through US-basedbanks). The firm’s representationresulted in OFAC issuing a licenceunfreezing the funds of the client.

The firm assisted a global leader inthe extractive industry with regard tosanctions compliance associated withauthorised Iranian-related operations,including firewalls for ensuring no USperson involvement and assessing itsglobalised IT systems for consistencywith OFAC requirements underGeneral License H.


Winner: Strong & Herd

Manchester, UK-based, Strong &Herd LLP (‘S&H’) was set up in 1995to operate as an external support tobusinesses in the areas of exportcontrol and customs compliance. Ithas a reputation for being practicaland hands-on in serving clients’ tradecompliance needs.

S&H was born out of the legaldepartment of Ferranti International,an international business heavilyinvolved in aerospace and defence,after the group had been defraudedduring a merger with a US company.S&H was set up initially to supportformer Ferranti Internationalbusinesses that were still viable afterthe corporate group was disbanded

under administrative receivership.Since 1995, the team has grown andS&H has also introduced training,consultancy and a cost-effectivehelpline service. Key team membersare Sandra Strong, Anthony Griffiths,Bernard O’Connor and Steve Berry.Sandra Strong is a popular speaker attrade compliance events who ‘knowsher nuts, bolts and widgets’.

The team assists clients incompliance with UK, EU and USexport controls and in dealing withembargoes and sanctions. It workswith clients to ensure they arecompliant with the law and also helpsintroduce efficiencies into their exportand import services.

With the planned UK departurefrom the EU, S&H has introduced a

new consultancy service, ‘Brexit:Supply Chain Planning’, whichfocuses on various areas of tradecompliance likely to be impacted,including export controls, sanctions,customs procedures. The team workswith clients to analyse how they

Export Controls Controls Consultant of the Year



currently operate under EUregulations so that when the changesare introduced, they are ready toadjust working practices accordingly.

Given that S&H rose out of theashes of a leading defence business, itcomes as small surprise that much –though not all – of the client base isdrawn from that sector. A quick peekshows clients are from

l Military and defence l Aerospace – civil and militaryl Marine – civil and militaryl Automotive – civil and militaryl Industrial manufacturing and

engineeringl Electronic/computer/softwarel Chemical and pharmaceuticall Textiles, clothing and household

goodsl Food and drink

A couple of examples of recentwork the team has been involved inillustrate its hands-on approach andthe real benefits that can be gainedfrom employing the right consultant.

A small UK business (18 staff) hadtraded with Iran when the sanctionswere in place and though it hadobtained licensing permission fromthe UK Export Control Organisation itfailed to obtain Treasury permissionto receive funds. The companyreceived a letter from the recentlyformed OFSI (Office of FinancialSanctions Implementation) requiringan explanation as to why this hadhappened and advising a correctiveaction plan. The company was given28 days to respond and threatenedwith high financial penalties and legalaction.

S&H was recommended to thecompany by the Department ofInternational Trade (‘DIT’) localbusiness advisor but this was twoweeks into its deadline. ‘We reshuffledour diaries,’ says Sandra Strong, ‘sowe could visit immediately, workingfor two full days pulling together thedetails for the reply and setting outthe corrective action plan whichincludes a written compliancestatement by the CEO, amendedwording in distributor contracts andregistration with key websites. OFSI istaking no further action and thebusiness feels able to develop itsexport market with confidence.’

In a second example, S&H wascontracted by a company that buildsand services military vessels (hoping

to obtain a new lucrative contract thatinvolved ITAR goods and technology)to train staff, including the engineerswho would be working within theITAR-controlled areas of the vessels,and to check and create ITARprocedures. S&H worked closely withthe company, developing itscompliance understanding and it wonthe order. According to S&H, ‘Theynow feel confident to pursue otherITAR business.’

A final word is for its well-regardedtraining services. S&H offers trainingin person and on line and alsoprovides offers an innovativetelephone support subscriptionservice called ‘One call’ by which, ‘fora very reasonable fee, users cancontact a consultant with an export(or import) query.’

Runner-Up: BPE Global

BPE Global is a women-owned,women-operated San Francisco,California-based global tradeconsultancy, offering ‘on-demand,flexible and focused’ services. Clientsspeak of the team’s ‘passion’ for whatthey do. The company has fourconsultants: Beth Pride (president, apopular and well-known ‘global tradeevangelist’) plus directors Julie Gibbs,Gabrielle Griffith and Renee Roe.

The team supports customers inevery industry except government andhas a truly global client base. Clientsare leaders in aerospace, defence andindustrials; consumer products andservices; energy and power; financial;healthcare; high technology;materials/renewable commodities;telecoms and service providers.

The team offers expertise in

l Determining jurisdictionl Country-specific controls

l Global product classification l Export licence and export permit

determination and applicationsl Technology transfers / deemed

exportsl Export declaration preparation and

submission (EEI, AES)l Restricted party screeningl Country research for country-

specific export regulationsl Freight-forwarder standard

operating proceduresl Voluntary self-disclosure

preparationl Selection and integration of a

global trade management systeml Online and in-person export

training development and deliveryl Policy and procedure developmentl Auditing, M&A assessments

The team is committed to going theextra mile for its clients. Beth Pridesays: ‘One of my favourite experienceswas getting a call on 4 July from aprivate equity firm telling me theywere acquiring three divisions of a $4billion medical device company. Theyhad just realised that tradecompliance was an essential part ofensuring a successful close on 31 July.The divisions were exporting andimporting from/to 159 countries. Theprivate equity firm engaged BPEGlobal to set up their global tradecompliance operations by 31 July. Allthree new companies were up andrunning without any supply chaindisruptions on 1 August. We workedwith each of the new companies,overseeing their global tradecompliance operations for the next sixmonths. We helped hire and traintrade compliance personnel and eachcompany was able to run theiroperations on their own within ninemonths of close.’

Now that’s what we callimpressive.

The team at BPE Global: from left to right, Julie Gibbs, Gloria Casey, Renee Roe,

Beth Pride and Gabrielle Griffith.



Winner: Clifford Chance

The past year has been unprecedentedin the history of Chinese telecomscompany ZTE. Its $1.19bn settlementwith US authorities for allegedsanctions violations is a landmark fineand a broadside for all non-USbusinesses wanting to have their cakeand eat it. But ZTE carries on, it’s stilldoing business in the US, it still has afuture in the global telecoms market.And for that, it can thank CliffordChance.

Equally, it’s unprecedented in thesepages to give two separate awards tothe same firm for the same piece ofwork. Indeed, some readers will nodoubt think that the fact that CliffordChance has been chosen for our ExportControls Law Firm (USA) shouldpreclude it from receiving this award.But we think not. The firm’sachievement for ZTE was the productof first-class lawyering in the US and inAsia and that should be recognised.(See the Export Controls Law Firm(USA) award write-up for full details.)

The Clifford Chance team, led andcoordinated by Wendy Wysong out ofDC and Hong Kong, included expertsin export control compliance, USsanctions laws and criminalinvestigations in the firm’s Hong Kong,DC, New York, Singapore, Beijing, andShanghai offices.

Basing itself in ZTE’s Shenzhen HQ,Clifford Chance worked with thecompany’s new management to correctthe information provided to the USgovernment concerning its historicalcompliance and sanctions issues, andguided the company in being fullytransparent with the US government.The firm led ZTE in producinghundreds of thousands of documents,translating them from Chinese toEnglish, and securing the vitalclearance for their production underthe China State Secrets Law, which hadoriginally prevented disclosure duringthe course of the investigation.

ZTE is the most talked-about exportexport controls matter of the past 12months. The scale of the company’sprevious violations and the size of thesettlements are remarkable. As was thelaw firm’s achievement. It was an

international matter which demandeda truly international effort and werecognise and applaud the lawyers inall of the firm’s offices for that.

Runner-Up: Rajah & Tann

Rajah & Tann is one of Singapore’slargest full-service law firms, withoffices in Singapore, Malaysia,Thailand, Indonesia, Vietnam andShanghai, and with lawyers on theground able to speak the local languageand qualified to advise on local law.

Export controls and sanctions workis carried out by the Trade Practicewhich offers a seamless service acrossthe region and unbeatable localknowledge. Key members of the teamare Kala Anandarajah, DominiqueLombardi, Tanya Tang and Kelvin Kho.

The firm offers expertise in thestructuring and implementation ofinternal compliance programmes toensure observance of both local andinternational export controls,managing controlled goods, employeetraining in compliance, obtainingpermits, classification of goods,valuation, and other areas such asimport verification.

The firm will coordinate matters forclients at a regional level and alsoadvise on the extraterritorial impact ofUS controls locally and on any conflictwith local regulations.

On the sanctions side, the teamadvises on embargoes involvingcountries such as Iran, Iraq, Liberiaand Libya, and also on the impositionof export-import boycott requirementsin trade agreements involving Israel.

The team is popular withmultinationals as well as localcompanies. In the past 18 months, itwas successful in getting a positivedecision in relation to a voluntarydisclosure made to Singapore Customsfor a leading technology company, atthe same time obtaining the necessarypermit for the export of strategicgoods. Currently, the firm is advisingthe client on simplifying its processesfor export and obtaining end-userstatement requirements. ‘Muchnegotiation has gone on with theSingapore Customs and with thecompany and its customer to find themost effective way to manage thismatter,’ the team reports

Another interesting instruction sawthe firm advise the Singaporesubsidiary of a US manufacturer ofprecision metal components oncompliance issues arising out of USexport controls and the laws ofSingapore and Indonesia, the latter apossible site for manufacture.

Highly commended

Global law firm Baker McKenzie

Export Controls/Sanctions Law Firm of the year,

Rest of the World

Kala Anandarajah, Rajah & Tann

The firm’s Trade Practice offers a seamless

service across the region and unrivalled local

knowledge..



has strength in trade complianceacross Asia and Australia. Drawing onits well-known international expertise,the firm

l Advised a global aerospace anddefence company in Australia on aseries of suspected export controlbreaches and on steps to take inmaking disclosures to regulators inmultiple jurisdictions. The matterinvolved consideration of recentlyenacted export controls forintangible transfers and wasespecially sensitive as it involves keygovernment contracts.

l Advised an Australia-based IT cloudservices provider with regard tochanges to sanctions against Iran.The client provides software

services in industries that werepreviously subject to sanctions andthe firm was instructed to advise onpossible new opportunities arisingin the lifting of the sanctions.

l Assisted a nuclear power companyon the revising, drafting and rollingout of a trade complianceprogramme in China.

India’s Economic Laws Practicereceived this award from WorldECR in2016. Partner Sanjay Notani is ‘the goto man’ for anything SCOMET-related.

During the past year, the firm

l Carried out a detailed review of theentire operations and activities of aleading multinational in theautomobile sector, with a view to

identifying the export regulationswhich require compliance, followedby a comprehensive riskassessment of existing processesand practices.

l Offered handholding and assistanceto various companies dealing ininformation technology, telecomm -unications and lighting to achieveclarification on their respectivesubjects of concern from theDirectorate General of ForeignTrade. This involved preparation ofapplications, obtaining relevanttechnical opinions from variousinstitutes in support of theapplications, reviewing the globalposition on the subject, as well asproviding necessary clarification asand when required.

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trade securityJournal

Issue 2 out nowessential reading for all trade compliance professionals

and their advisors - six times a year

Issue 2 contents include

Labour and human rIghtsNew US forced labour import ban – challenges for business

smart practIceHow well do you know your customer? Successful restricted partyscreening guidance

Doing business in China – how to avoid common pitfalls

natIonaL securItyTrump administration highlights limitations of CFIUS process

data prIvacy and securItyChina’s new cybersecurity law and its impact for non-Chinesecompanies

South Korea Joins APEC's Cross-Border Privacy Rules System

US Supreme Court to hear major cellphone privacy case

The future of data privacy in the United Kingdom post-Brexit

Switzerland to modernise data protection law

antI-corruptIon and amLNew ISO Anti-Bribery Standard for Singapore

The Odebrecht contagion: the bribery scandal rocking the world

Is your organisation prepared for the EU Fourth Anti-MoneyLaundering Directive?

taLkIng trade securIty: With Eddie Rich of EITI

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