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Basics of Export Controls 2014

Speaker(s): Kimberly A. Strosnider, Sanjay Jose Mullick
Recorded on: Dec. 1, 2014
PLI Program #: 127637

Sanjay Jose Mullick concentrates his practice in export controls, economic sanctions, international dispute resolution and international trade regulation. He has a broad range of experience providing counsel to companies on export control matters administered by the Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR) and the Directorate of Defense Trade Controls (DDTC) under the International Traffic in Arms Regulations (ITAR), as well as economic sanctions administered by the Office of Foreign Assets Control (OFAC). Mr. Mullick advises governments and companies in international arbitration and litigation, including dispute resolution proceedings under the investment provisions of the North American Free Trade Agreement (NAFTA) and bilateral investment treaties, administered under the rules of the International Center for the Settlement of Investment Disputes (ICSID) and the United Nations Committee on International Trade Law (UNCITRAL). He represents clients in trade remedy proceedings, including antidumping and countervailing duty investigations and suspension agreements before the Department of Commerce, the International Trade Commission and the Court of International Trade. He is a member of the Firm's India practice.

Kim Strosnider advises companies on the application of international trade controls and has represented clients in litigation and arbitration matters. She currently serves as a vice-chair in the firm’s International practice group, focusing on trade controls.

In the international trade area, Ms. Strosnider counsels clients on US export controls administered by the Departments of State, Commerce, and Energy and the Nuclear Regulatory Commission; economic sanctions programs administered by the Treasury Department; import and licensing requirements imposed by the Bureau of Alcohol, Tobacco, Firearms and Explosives; and compliance with US anti-boycott laws. She has counseled companies in the manufacturing, defense, energy, nuclear, pharmaceutical, and medical device sectors, among others.

In litigation matters, she has represented clients in state and federal court and before arbitration panels, chiefly in insurance coverage disputes. 

Representative Matters

Advise clients on all facets of foreign trade control compliance, including the application of export controls, including interpreting and applying regulatory requirements related to exports/reexports and the application of US sanctions programs.

Help companies understand and evaluate export control reform initiatives and file comments with agencies in response to proposed regulatory changes.

Assist with the development and implementation of compliance initiatives (including policies, procedures, and manuals) and provide foreign trade controls training to company personnel.

Counsel clients on the application of US export controls in emerging markets such as China.

Conduct internal investigations into foreign trade control violations and assist clients in preparing voluntary self-disclosures to the Departments of State and Commerce, and implementing corrective compliance measures in the wake of those disclosures. 

Advise clients on the drafting/preparation of license applications, proposed technical assistance and manufacturing license agreements, commodity jurisdiction ruling requests, and registrations with the State Department’s Directorate of Defense Trade Controls.

Represent various bidders in acquisitions by spearheading due diligence efforts with respect to target companies’ compliance with US export controls and other industry-specific regulations.

Counsel clients in the medical-device sector on the application of US Syria and Iran sanctions and humanitarian licensing programs.

Previous Experience

Journalist for newspapers in Ohio, Pennsylvania, Maine, and Washington, DC (1989-1998)

Pro Bono

Represented African immigrant in obtaining green card.
Assisted non-profit in navigating the child-placement laws of Washington, DC and various states.

Memberships and Affiliations

Society for International Affairs, Associate Member