Regulatory
International Trade
Every day Gibson Dunn’s experienced team helps clients navigate fluid global trade regulations, manage complex regulatory enforcement matters, and secure vital authorizations for compliant operations.
75+ lawyers across 15 offices worldwide
Practice led by former government officials and architects of trade regulation
Our practice and its lawyers have repeatedly been recognized for their work, including in Chambers USA, Chambers Global, and Who’s Who Legal
Chaired by the 16th United States Trade Representative (USTR) and former Senior Advisor to the Director of OFAC
Overview
Global Expertise and Deep Understanding
Our international team possesses a profound understanding of the federal departments and global agencies that implement and enforce import, export, customs, transnational investment, and unfair trade laws and regulations.
Comprehensive Trade-Related Services
We assist clients worldwide with a broad spectrum of trade-related matters, including:
- U.S., EU, U.K., and UN economic and trade sanctions including regulator engagement and civil and criminal enforcement matters
- Export controls including with respect to high technology and other sensitive goods
- Import controls related to human rights concerns
- CFIUS and foreign direct investment reviews
- Customs
- Antidumping and countervailing duties
- Trade litigation and agency representation
- Trade and investment policy
- National security
Strategic Advantage and Compliance
We believe that companies with robust, responsive compliance programs have a competitive advantage. They can pursue opportunities that others overlook. Leveraging our credibility with leading authorities and our command of relevant regulations, we help clients develop integrated, business-savvy compliance systems to mitigate risk. When investigations or disclosures are necessary, we draw on cross-sector experience to create defensible and compelling plans that identify root causes, inform corrective actions, vigorously defend clients against agency enforcement actions, and rebuild agency confidence in our clients.
Unparalleled Global Experience
Our lawyers have extensive global experience across Asia, Europe, the Gulf, and the Americas, with many having served as principal architects of key sanctions and export control regimes. We have been at the forefront of historic changes in U.S. sanctions and export control policies toward China, Russia, Venezuela, Iran, and other jurisdictions, advising policy makers and testifying before government committees. We have helped clients manage the most consequential trade enforcement actions in history and have led some of the only successful judicial challenges to trade regulations. We also help clients navigate complex landscapes and secure difficult-to-obtain export controls and sanctions authorizations.
Integrated Team Approach
Our international trade experts work closely with Gibson Dunn’s white-collar investigation, national security, regulatory, transactional, and litigation teams, offering a deep bench of expertise globally. Recognizing the interconnected nature of regulatory risks, we take a holistic approach to better address our clients’ needs.
Core Areas of Expertise
Our international trade compliance expertise focuses on five core areas:
- Compliance Counseling and Licensing
- Program Design, Implementation, and Evaluation
- Compliance Outreach with Key Third-Party Stakeholders to avoid de-risking and ensure that intermediaries are confident in the compliance practices of clients
- Internal Investigations concerning Trade Related matters and Crisis Management
- Representations in enforcement matters before International Trade Authorities throughout the world
Complex and Sensitive Representations
Our lawyers have represented multinational corporations and financial institutions in some of the most legally complex and politically sensitive cases, including those involving Artificial Intelligence, sophisticated technologies (such as semiconductors), and supply chain risks and management. Few firms can match our global presence, comprehensive experience, and deeply talented team.
“The team has a thorough understanding of the international sanctions regimes and are able to find appropriate, commercial solutions.”
Chambers USA
Experience
Recent representations include:
- Represented a medical device manufacturer in obtaining appropriate Bureau of Industry and Security (BIS) classification for shipment to countries subject to economic sanctions.
- Represented a non-U.S. cryptocurrency exchange in a historic resolution with DOJ and OFAC, among other agencies, resolving allegations including purported violations of U.S. sanctions laws predicated upon novel theory.
- Represented a global asset management company in CFIUS and ITAR compliance matters, successfully clearing CFIUS review within 45 days without mitigation measures.
- Advised an international investment group on multiple CFIUS matters, including portfolio investments and restructurings involving four U.S. businesses across healthcare, financial services, and aerospace sectors.
- Represented a private equity company on CFIUS matters for a $290 million cross-border acquisition of an electric power systems provider, jurisdictions included Bahrain, Canada, and the U.S.
- Advised a major global e-commerce company and its subsidiary on economic sanctions compliance related to restrictions involving Russia and Belarus.
- Advised a leading provider and manager of alternative investment products in the acquisition of a 50% interest in a global private equity company’s infrastructure business. We assisted with CFIUS strategy and the filing process, clearing CFIUS with no mitigation in the 45-day review period.
- Advised a U.S. public payments companies and its global subsidiaries, on a full spectrum of US, UK and EU economic sanctions compliance, particularly with respect to the new sanctions against Russia and Belarus arising from the war in Ukraine.
- Successfully represented a regional financial institution before OFAC and other agencies in responding to a subpoena following revelations of potentially sanctionable conduct.
- Advised a global social networking and technology company about U.S. sanctions and anti-money laundering compliance issues, including regulatory guidance, investigations, and advocacy before OFAC with respect to the agency’s request for information.
Practice Leaders
News & Insights
Client Alert
A Committee of Consequence: CFIUS Debuts Record Penalties, Expands Jurisdiction
Client Alert
Proposed Rules Call for Significant Restrictions on Facial Recognition Technologies, Defense Services, U.S. Persons Activities, and New Classes of Foreign End-Users
Client Alert
The Long Arm of EU Sanctions? Latest EU Sanctions on Russia and Belarus Extend to Non-EU Subsidiaries and Introduce Mandatory Risk Assessment