Trade Regulation, Export Controls & Sanctions

Featured Publication:

Managing Supply Chain Consequences Of Russian Sanctions

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.

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International trade has long been heavily regulated, but today’s cross-border transactions are coming under greater governmental scrutiny than ever before—and regulatory violations can lead to significant civil and criminal penalties. The importance of keeping up to date in this area was particularly brought to the fore in light of Russia’s invasion of Ukraine in March 2022, and the sanctions that flowed from that conflict. Given the complexity of global transactions and the pace of regulatory change, compliance is not easy. Cozen O’Connor provides comprehensive international trade counsel and advocacy designed for the modern era.

The firm represents clients from diverse industries at all stages of a transaction. We work with ocean and inland carriers, technology companies, manufacturers, global shippers and individual executives, both foreign and domestic, in connection with U.S. and international trade regulations.

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.

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 the myriad economic sanctions regimes. We frequently counsel clients regarding export licensing, commodity classification, anti-boycott regulations, and trade restrictions involving embargoed countries and sanctioned individuals and entities. Our team stays on the cutting edge of trade issues involving hot-button countries including Russia, China, Iran, Cuba, and others. We advise clients on U.S. Customs regulations relating to duties and tariffs, documentation requirements, contraband, cargo clearance and supply-chain security.

Our primary goal is to help clients achieve compliance with U.S. trade regulations while supporting their business objectives. Cozen O’Connor attorneys routinely perform high-level audits, design compliance policies, provide on-site training and advise on major transactions. We also 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.

We work closely with each client to create workable, practical and tailored strategies. What distinguishes Cozen O’Connor is not just that we understand the vast and complicated set of constantly shifting regulatory requirements, but also the operational realities of the industries we are supporting.

Experience

Publications

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.

Venezuela: Not an Embargo, but Closer

August 08, 2019

In a significant escalation of economic pressure on Venezuela’s Maduro regime, President Trump issued an executive order on August 5 that blocks all Venezuelan government property in the U.S. or in the possession of U.S. persons.

OFAC Issues Iran-Related Civil Aviation Industry Advisory

July 30, 2019

Don Kassilke and Bob Foster discuss OFAC's Iran-Related Civil Aviation Industry Advisory and why it could mean OFAC will be taking a greater interest in the Iranian aviation sector.

Droning On: Trump Administration Calls for Additional Sanctions on Iran [Alert]

June 26, 2019

Don Kassilke and Matt Howell discuss the largely symbolic new round of sanctions specifically targeting the senior leadership of the Iranian regime.

OFAC Issues Compliance Guidance to Companies [Alert]

May 09, 2019

Stephen Miller and Rachel Collins Clarke discuss OFAC's expectations for effective sanctions compliance programs.

U.S. Lowers the (Oil) Boom on Venezuela [Alert]

February 05, 2019

Don Kassilke and Matt Howell discuss Executive Order 13850 and why it is important entities that have dealings with PdVSA or any of its related entities carefully review the restrictions and general licenses published by OFAC to ensure compliance with applicable OFAC regulations.

OFAC Announces Imminent Termination of Rusal Sanctions [Alert]

December 20, 2018

Don Kassilke and Matt Howell discuss the Treasury Department's decision to terminate sanctions imposed on En+ Group PLC, United Company Rusal PLC ), and JSC EuroSibEnergo, three companies placed on the SDN list because they were owned or controlled by Oleg Deripaska, a Russian oligarch sanctioned pursuant to Executive Orders 13661 and 13662.

U.S. Completes Withdrawal from Iran Nuclear Deal [Alert]

November 06, 2018

Don Kassilke and Matt Howell discuss the conclusion of the wind-down periods and the United State's return to the pre-JCPOA status quo with regard to most secondary sanctions.

Russia-Iran-North Korea Sanctions: Congress Makes a Statement [Transportation & Trade Alert]

August 01, 2017

Donald Kassilke, Robert Freeman, and Jennifer Urban discuss The ‘‘Countering America’s Adversaries Through Sanctions Act’’ that is composed of three distinct titles each of which mandates the development of various reports and sets out certain mandatory and discretionary sanctions for implementation by the executive branch.

Events & Seminars

Past Events

EMLO 2017 Spring Seminar

April 27, 2017 - Genoa, Italy

In The News

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.

Jeffrey Lawrence Named Co-Chair of the International Transportation Committee of the ABA International Law Section

October 21, 2020

Cozen O’Connor is pleased to announce that Jeffrey Lawrence, chair of the firm's Transportation & Trade Group, has been named co-chair of the International Transportation Committee of the ABA International Law Section.

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

August 20, 2020

Best Lawyers selected 201 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.

Contacts

Jeffrey F. Lawrence

Co-Chair, International Practice

jlawrence@cozen.com

(202) 463-2504

People

Awards

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.

Jeffrey Lawrence Named Co-Chair of the International Transportation Committee of the ABA International Law Section

October 21, 2020

Cozen O’Connor is pleased to announce that Jeffrey Lawrence, chair of the firm's Transportation & Trade Group, has been named co-chair of the International Transportation Committee of the ABA International Law Section.

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

August 20, 2020

Best Lawyers selected 201 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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