Export Control and International Economic Sanctions

We provide support and advice on export control law, assisting, in particular, companies that operate in countries subject to economic sanctions (such as Iran or Russia).

We have developed a specific expertise in conducting trade-focused risk assessments, in helping clients design and implement tailored, risk-based compliance programs, and in providing practical, day-to-day advice on economic sanctions and export controls issues.

We assist companies constantly interacting with the Italian Ministero degli Affari Esteri e della Cooperazione Internazionale (MAECI) and/or with US federal agencies that oversee trade policy, including the Bureau of Industry and Security (BIS) and the Office of Foreign Assets Control (OFAC).

In particular, we assist clients in:

• complying with dual use and economic sanctions provisions. We cooperate with engineers and other professionals when drafting opinion letters relating to exports of items (including software and technologies) to be carried out in compliance with the law;
• conducting risk assessments in order to determine the economic sanctions and export control risks. In response, we help clients determine how best to build and strengthen their compliance programs (“Internal Compliance Program”) and assist in the ongoing monitoring of those programs;
• training personnel on compliance best practices;
• conducting internal investigations and handling related criminal and civil cases that may arise in such matters;
• taking corrective actions (for example voluntary disclosure) and preserving of any export privileges;
• determining commodity classification and applying for export license;
• identifying and efficiently mitigating any economic sanctions and export controls risks arising out of corporate transactions that may give rise to such risks;
• negotiating and drafting international commercial contracts, drafting clauses safeguarding the company in export control and economic sanctions matters;
• screening parties with whom companies conduct their business;
• verifying corporate governance aspects of the companies, in order to safeguard the companies and top-management.

In particular, we have extensive experience in supporting corporate groups with manufacturing and/or distribution centers in Italy and in the United States.