Import and Export Compliance
Troutman Sanders LLP represents clients on a broad range of import and export issues which arise under the relevant U.S. laws and regulations. The firm's multi-faceted International Trade Team includes attorneys and professionals who have extensive experience on all aspects of international trade regulation matters.
The Team assists clients with trade compliance regulation matters before the Departments of State, Commerce, Treasury, Homeland Security, and Defense. This representation includes licensing, compliance and enforcement under the Export Administration Act, the Arms Export Control Act, Trading With the Enemy Act, International Traffic in Arms Regulations, Foreign Assets Control regulations, Export Administration regulations, country-specific trade sanctions/trade embargo regulations. Compliance with these U.S. import and export controls and regulations is important to U.S. national security, in order to protect U.S. interests at home and abroad. We work closely with our clients to ensure their exports are conducted legally. Compliance not only involves controlled goods and technologies, it also involves restrictions on shipping to certain countries, companies, organizations, and/or individuals.
Our team has extensive experience in developing export control corporate compliance programs both in the United States and abroad. Such work includes internal audits, due diligence reviews and implementation of compliance measures addressing both Department of Commerce (dual-use goods, software and technology) and Department of State (defense articles and services) regulations and enforcement matters. In 1988, a member of the firm developed the Model Strategic Products Export Control Program that was adopted by Japan's Ministry of International Trade and Industry (MITI).
Our work in the area of export control and compliance also encompasses assisting clients with any registration and licensing activity, including commodity classification requests and commodity jurisdiction (CJ) requests to determine whether an item or service is covered by the Commerce Control List (CCL) or the U.S. Munitions List (USML). In addition, our experience also involves providing counsel for any self-disclosure for violations or defending in any investigations or enforcement actions by U.S. agencies, and in working towards mitigating any penalties. The majority of this work is before the Office of Foreign Assets Control (Treasury - OFAC), the Bureau of Industry & Security (Commerce - BIS), and the Directorate of Defense Trade Controls (State – DDTC).
The Team provides advice and counsel to U.S. importers with regard to a wide variety of matters before U.S. Customs & Border Protection (CBP) including classification, valuation, country of origin marking, investigations and rulings, and homeland security regulations. Troutman Sanders attorneys represent large international manufacturers in enforcement and penalty actions commenced by CBP and have experience litigating disputes before the Court of International Trade.
In the area of international logistics, the Team’s attorneys have broad commercial and legal experience in supply chain logistics, and have advised large international corporations with regard to all manner of contract and commercial issues arising out of the ocean and air transportation of goods. Since September 2001, Troutman Sanders has worked on international transportation security-related issues before Congress and the Departments of Homeland Security and Transportation, including port and container security programs and the Transportation Workers Identification Credential (TWIC) program.
In addition to advising clients on technical aspects and regulatory applications of U.S. import and export control laws, our attorneys and professionals practicing in this area have the experience to provide clients with guidance on all aspects of political and policy developments in Congress and the Executive Branch related to trade regulations and compliance.