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U.S. Sanctions Relating to the Unrest in Ukraine: Compliance Challenges


Speaker(s): Corinne A. Goldstein, Stephan E. Becker
Recorded on: Oct. 9, 2014
PLI Program #: 61512

Corinne Goldstein counsels clients on US export controls, economic sanctions, and anti-boycott programs. She advises leading companies in the financial services, oil and gas, pharmaceutical, biotechnology, defense, and general manufacturing sectors. Her work includes advising on interpretive issues, developing compliance and training programs, securing licenses, and representing clients in enforcement proceedings.

Ms. Goldstein has served as the Managing Partner for Legal Personnel, the Chair of the Summer Associate Program, the Chair of the Diversity Committee, and as the Chair of the Evaluation Committee.

Representative Matters

  • On behalf of an Audit Committee, conducted a significant internal investigation of sales by a US energy-sector company and its foreign affiliates to US-sanctioned countries and prepared a voluntary disclosure to the US Treasury and Commerce Departments concerning the findings of the investigation.
  • Advised major international oil & gas companies concerning the application of US sanctions against Iran, Syria, and other US-sanctioned countries to their businesses.
  • Represented a major non-US financial institution in connection with an investigation into its processing of US dollar transactions for US-sanctioned parties.
  • Advised a major banking institution concerning the application of US foreign trade controls to various investment and financial activities and trained bank employees.
  • Developed sanctions compliance policies and procedures for a major financial institution.
  • Developed policies and procedures relating to foreign trade controls compliance for a medical device company and a scientific research company.
  • Advised a major defense company concerning the application of the State Department regulations to exports of defense articles and disclosure of controlled technology.

Publications

  • "United States, EU, Other Global Powers Reach Comprehensive, Long-Term Nuclear Deal with Iran," Covington Alert (7/15/2015), Co-Author
  • "Iran Sanctions Relief - On the New Horizon," Money Laundering Bulletin (4/28/2015), Co-Author
  • "Developments in U.S. and EU Sanctions Against Russia and the Occupied Crimea Region of Ukraine," Covington E- Alert (12/24/2014), Co-Author
  • "EU Updates Existing Sanctions Against Russia; US Issues Guidance and Moves to Impose Additional Sanctions," Covington E-Alert (12/17/2014), Co-Author
  • "President Obama Announces Significant Relaxation of U.S. Sanctions Against Cuba," Covington E-Alert (12/17/2014), Co-Author
  • "U.S. Commerce Department Announces Restrictions on Items Intended for Military End Uses and Military End Users in Russia," Covington E-Alert (9/22/2014), Co-Author
  • "U.S. and EU Significantly Expand Sanctions and Export Control Restrictions Targeting Russia," Covington E-Alert (9/13/2014), Co-Author
  • "OFAC Issues New Guidance Regarding Entities Owned by One or More Designated Parties," Covington E-Alert (8/15/2014), Co-Author
  • "U.S. Commerce Department Restricts Energy-Related Exports and Reexports to Russia," Covington E-Alert (8/12/2014), Co-Author
  • "European Union Issues New Sectoral Sanctions Against Russia," Covington E-Alert (8/4/2014), Co-Author
  • "Developments in EU and U.S. Sanctions: Russian Financial, Energy, and Defense Sectors Targeted with Coordinated New Sanctions; Additional Export Controls Restrictions, Investment Restrictions, and Asset-Blocking Measures Imposed," Covington E-Alert (7/30/2014), Co-Author
  • "Sanctions Update: U.S. and EU Extend Limited Sanctions Relief Related To Iran; EU Agrees to New Sanctions Against Russia," Covington E-Alert (7/23/2014), Co-Author
  • "U.S. Treasury Department Implements New Sanctions Targeting Russian Financial and Energy Sectors; Names New Blocked Parties -- EU Imposes Additional Sanctions Related to Ukraine Crisis," Covington E-Alert (7/17/2014), Co-Author
  • "U.S. State and Commerce Departments Issue Final Rules Amending Export Controls Applicable to Military Electronics," Covington E-Alert (7/10/2014), Co-Author
  • "OFAC Makes Significant Revisions to Its SDN List: Removal of Hundreds of Designated Narcotics Traffickers, Additional Listing of Parties in Ukraine," Covington E-Alert (6/23/2014), Co-Author
  • "State and Commerce Departments Publish Interim Final Rules Implementing Satellite Export Control Reform," Covington E-Alert (5/23/2014), Co-Author
  • "Further Developments in the EU Sanctions Relating to Ukraine," Covington E-Alert (5/13/2014), Co-Author
  • "OFAC Publishes New Syria and Ukraine Sanctions Regulations Designates Russian Bank for Its Involvement in Syrian Unrest," Covington E-Alert (5/12/2014), Co-Author
  • "Recent Developments in the EU Sanctions Relating to Ukraine," Covington E-Alert (4/29/2014), Co-Author
  • "Recent Developments in Sanctions Relating to Ukraine,"
  • Covington E-Alert (4/28/2014), Co-Author
  • "Recent Developments in Sanctions Relating to Ukraine and South Sudan," Covington E-Alert (4/15/2014), Co-Author
  • "United States Expands Sanctions Related to Ukraine Crisis; Additional Russian and Ukrainian Parties Designated," Covington E-Alert (3/21/2014), Co-Author
  • "United States and European Union Impose Additional Sanctions in Response to the Crisis in Ukraine," Covington E-Alert (3/18/2014), Co-Author
  • "United States and European Union Impose Sanctions Related to Unrest in Ukraine," Covington E-Alert (3/6/2014), Co-Author
  • "Russian Intervention in Ukraine," Covington E-Alert & Advisory (3/5/2014), Co-Author
  • "U.S. Treasury Department Amends and Expands General License for Personal Communications Devices, Software, and Services to Iran," Covington E-Alert (3/4/2014), Co- Author
  • "Sanctions Update: U.S. and EU Ease Sanctions Against Iran," Covington E-Alert (1/22/2014), Co-Author

Representative Presentations and Speeches

  • “Clients in Distress - Bankruptcy and Sanctions,” Futures Industry Association (2015)
  • “Focus on Iran: A Comprehensive Review of Permissible and Prohibited Activities Involving Iran in Light of Easing Sanctions,” American Conference Institute (2014)
  • “U.S. Sanctions Relating to the Unrest in Ukraine: Compliance Challenges,” Practising Law Institute (2014)
  • “Coping with U.S. Export Controls 2013: OFAC Sanctions Update,” Practising Law Institute (2013)
  • “New Developments in US Sanctions,” Institute of International Bankers Seminar on Risk Management and Regulatory Examination/Compliance Issues Affecting International Banks (2012)
  • “US Economic Sanctions,” International Chamber of Commerce (2012)
  • “Managing Heightened Diversion and Facilitation Risks: New Red Flags to Detect Before It Is Too Late,” American Conference Institute (2012)
  • “US Economic Sanctions: Highlights and Recent Developments,” American Petroleum Institute (2012)
  • "US Sanctions Developments,” American Bar Association (2011)

Practices

  • International
    • International Trade Controls
  • Environmental

Industries

  • Life Sciences
  • Aerospace, Defense and National Security
  • Energy & Natural Resources

Education

  • University of Michigan Law School, J.D., 1976
    • magna cum laude
    • Order of the Coif
    • University of Michigan Law Review, Note Editor
  • Wellesley College, B.A., 1973
    • with Honors

Bar Admissions

  • District of Columbia


Stephan E. Becker
Partner

Mr. Becker is the leader of the law firm's International Trade practice. His practice encompasses a broad range of legal subjects in the areas of international trade regulation and international law. He works with companies in a wide variety of industries, including semiconductors, aerospace, electronics, software, energy, and agriculture.

Mr. Becker regularly advises companies on export control restrictions and embargoes, including those imposed under the Export Administration Regulations, International Traffic in Arms Regulations, and Assets Control Regulations, and in matters relating to obtaining license approvals, establishing internal corporate compliance programs, and determining whether proposed transactions are permitted. Mr. Becker has defended companies in both administrative and criminal enforcement actions involving alleged violations of the export control laws. Mr. Becker often speaks at conferences on export controls and embargoes.

Mr. Becker is an authority on international trade agreements and public international law and has advised several foreign governments on a variety of issues relating to their treaties with the U.S. He has been involved in numerous international dispute settlement proceedings conducted under the rules of regional trade agreements, the World Trade Organization, and the International Centre for the Settlement of Investment Disputes.

Mr. Becker is a member of Pillsbury's Foreign Corrupt Practices Act (FCPA) Task Force. He regularly counsels clients on compliance with the FCPA, including by assisting them in creating and implementing compliance policies and programs, providing training, analyzing transactions for potential FCPA liability, and conducting internal investigations.

Mr. Becker has extensive experience with customs law matters, including rules of origin, valuation, and tariff classification issues, government audits, and civil and criminal enforcement proceedings. He assists companies in establishing internal compliance programs and counsels clients on how they can benefit from free trade agreements and other duty reduction programs, both in the U.S. and abroad.

Mr. Becker also advises on compliance with the Exon-Florio Amendment, which is administered by the Committee on Foreign Investment in the United States (CFIUS) and allows the President to block foreign acquisitions of U.S. companies that are deemed vital to U.S. national security, including "critical infrastructure." He represents both domestic and foreign companies in preparing submissions to CFIUS and complying with the various legal obligations that can arise when foreign interests invest in the United States.

Mr. Becker also represents companies, industry associations, and foreign governments in antidumping and countervailing duty investigations before the International Trade Commission and the U.S. Department of Commerce, as well as in other types of trade remedy proceedings such as safeguards, Section 301, and Section 332 investigations, and appeals to the Court of International Trade and the U.S. Court of Appeals for the Federal Circuit.

At Columbia University Law School, Mr. Becker was Notes and Comments Editor of the Columbia Law Review. He has been an adjunct professor at Georgetown University Law Center, where he taught a course on international trade agreements.

Mr. Becker is acknowledged as a leading International Trade lawyer in Chambers Global: The World's Leading Lawyers for Business and Chambers USA: America's Leading Lawyers for Business in the category International Trade: Trade Remedies & Trade Policy.

Honors & Awards

  • Chambers Global, International Trade: Trade Remedies & Trade Policy—USA (2008-2013)
  • Chambers USA, International Trade: Trade Remedies and Trade Policy—National (2007-2013)
  • Legal 500 Latin America, Corporate M&A (2013)
  • Super Lawyers, International Trade (2013)

Affiliations

American Bar Association

Courts

U.S. Supreme Court, Court of International Trade, District of Columbia Court of Appeals, U.S. District Court for the District of Columbia, U.S. Court of Appeal for the District of Columbia, Federal, Seventh and Ninth Circuits

Recent Speaking Engagements
 
“Recent Developments in Investment Arbitration,” presentation at the annual meeting of the Berne Union association of private and governmental export credit insurers, April 23, 2013, Jersey City, New Jersey.
 
“Export Enforcement Issues,” U.S. Export Controls & Defense Trade Controls Seminar Series, hosted by Export Compliance Training Institute, Chicago, IL, September 16, 2011
 
“Compliance Planning II – Is Your House Made of Straw, Sticks or Bricks? Manufacturing and Defense Industry Planning,” Coping with U.S. Export Controls 2010, hosted by Practicing Law Institute, Washington, DC, December 7, 2010
 
“The Intersection of E&C and Export Control Regulations,” Ethics & Compliance Officer Association’s 8th Annual Ethics and Compliance Conference, September 22, 2010
 
"Export Enforcement Issues,” U.S. Export Controls & Defense Trade Controls Seminar Series, hosted by Export Compliance Training Institute, Chicago, IL, September 15, 2009
 
"The Extraterritorial Reach of US Sanctions: OFAC’s Application to Foreign Parties and Activities," Economic Sanctions Conference, hosted by American Conference Institute, February 2009
 
“Preventing Liability for Foreign Party Violations of U.S. Export/Reexport Controls,” Annual Forum on Export Controls, hosted by American Conference Institute, May 2009

Practices / Industries

International Trade
    Foreign Corrupt Practices Act & Global Anti-Corruption

Aviation, Aerospace & Transportation
Consumer & Retail
Litigation 
    Appellate 
    Arbitration & Alternative Dispute Resolution

Technology
Semiconductor
Latin America
Korea
    Anti-Money Laundering

Focus Teams
Crisis Management

Admissions
District of Columbia

Education
J.D., Columbia University School of Law, 1982
Law Review

B.A., Yale University, 1979