w350)ecr a:& 2016 w350)ecr a:& 2016 awards 2016 · anti-boycott laws, anti-money laundering...

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1 WorldECR www.worldecr.com

For the second year, WorldECR isproud to present awards forexcellence in export controls and

sanctions practice. Launching theawards last year, we said they should‘recognise outstanding work, vision,best practice, commercial benefit to thecompany, and contribution tointernational security, of organisationsand individuals working in the fields ofexport control and sanctionscompliance and nonproliferation.’ Onceagain, the winners, runners-up andcommended parties have demonstratedthese achievements in buckets.

In the build-up to the inauguralawards, I wrote: ‘It is time that theexcellent work carried out by exportcontrol compliance professionals isrecognised and celebrated – not just bythis community but also by colleaguesin other departments in theircompanies and beyond. Equally, thecontribution of specialist export controland sanctions law firms andconsultancies should not go unnoticed.Their contribution to their clients’business success and also to fightingproliferators deserves championing.’

The feedback that we received on

last year is that these awards do justthat, championing the work of thiscommunity of key professionals.

A year on and the raison d’etre hasnot changed. By the end of April, wehad received a raft of excellentnominations and submissions toconsider. As can be expected, in somecategories the competition wasespecially tough – the sanctions lawfirm categories being a prime example.Yet, throughout all categories, wereceived evidence of real achievementand innovation, of commitment andcreativity, of willingness to go the extramile, from those in industry andinstitutions, in law firms, and inspecialist consultancies.

What is remarkable is the variety oftype and background of those putforward; from global powerhouses totwo-man bands, each playing their partin making the world a safer place. (In

many instances, the names of clientsand much of the work carried out mustremain confidential.)

The team at WorldECR would like tothank every individual and everyorganisation who sent us a nomination,an endorsement for a third-party,additional information where we felt itwould benefit our decision making, andto congratulate not just the winners butevery person – natural and legal – thatmade our shortlists. We weren’t able toreply to everyone who put in anomination or submission with athank-you at the time, but we do thankyou now.

We’d also like to thank our panel ofjudges who gave up precious – andsometimes billable – time to review andconsider the shortlists and rule on theresults.

Mark Cusick

Publisher, WorldECR

AWARDS 2016The WorldECR Awards recognise the achievement of export controls and sanctions professionals.

WorldECR Awards 2016 WorldECR Awards 2016

Supported by



Winner: Chester Paul Beach

‘Paul Beach has been instrumental in

driving change across industry,

leading the trend towards the

development of a fully comprehensive

trade compliance function. Paul’s

leadership, honesty and integrity

about his Consent Agreement

experience and his commitment to

building a world class trade

compliance programme has been

well received by industry and has

proved valuable to a number of other

leaders who were looking to drive

meaningful change across their

organisations. His legacy speaks for

itself and his name should be added

to the export control “hall of fame”!’

Stacey Winters, Global ExportControls and Sanctions Leader,Deloitte LLP

Chester Paul Beach, who retired fromthe position of Associate GeneralCounsel, International TradeCompliance at United Technologies inJanuary this year, is WorldECR’sExport Control Practitioner of theYear, 2016. ‘I didn’t know he’d retired.That’s a great loss to the exportcontrol community,’ commented oneU.S. government export controlsprofessional.

Paul Beach spent more than 20years at UTC and associatedcompanies, finishing his career at thecompany as Senior UTC executiveresponsible for driving UTC’sinternational trade complianceprogramme, chairing the UTC-wideInternational Trade ComplianceCouncil, and supervising UTC’sWashington-based CorporateInternational Trade ComplianceOffice and enterprise-wideInternational Trade ComplianceProgram Office. His remit includedoverseeing development andperformance of more than 650 full-time ITC professionals across UTC.

When, in June 2012, UTC enteredinto settlements with the departmentsof Justice (deferred prosecutionagreement (DPA)) and State (consentagreement) stemming from pastviolations of the ITAR, Charles Gill,the company’s Executive Presidentand General Counsel, asked Beach to

lead a much-needed transformation ofUTC’s International TradeCompliance (‘ITC’) programme. Gillwrites: ‘[Beach] was clearly the rightperson for the job. Paul tirelessly ledthe development and implementationof a comprehensive UTC ITCprogram. Our goal is sustainableworld-class excellence in all aspects oftrade compliance. While we willcontinuously improve our program,key features developed under Paul’sleadership include:

l A “hub-and-spoke” oversightinfrastructure that drives: (i)common corporatewide ITC policyand process deployment; (ii)business ownership of compliance,including business implementationof UTC requirements under theoversight of UTC business unitcore ITC groups; and (iii) UTCoversight of business unitimplementation of thoserequirements;

l Increase in functional full-time ITCstaffing to more than 595professionals worldwide (with atotal of 649 approved positions),including ITC personnel in coreITC functions and embedded inbusiness operations;

l Substantial increase of function-specific online and in-personawareness and specialist training,together with an ongoing, brandedUTC-wide communicationsprogram to reinforcemanagement’s commitment to aculture committed to full tradecompliance;

l A robust, ongoing UTC Self-Assessment process applied acrossUTC’s aerospace business units toassure that all identified business

processes include necessary tradecompliance controls, withcontinuous improvement throughanalysis of results from audits andinvestigations;

l Significant investments inintegrated IT automation, usingcommon enterprise platformsintegrated with foundationalsystems for jurisdiction andclassification, access controls andlogging;

l Management of export licensesand agreements by individually-accountable owners trained toexecute common standard work,with quarterly ownercertifications;

l Robust transparency through anautomated matter managementsystem that captures tradecompliance questions andconcerns directly from employeesand tracks them to response andresolution, with a strong analyticscapability to enable the companyto identify and address compliancepriorities using continuousimprovement disciplines; and

l Timely investigation of instancesof non-compliance and disclosuresof violations, coupled withresponsive corrective actions.

While building our program, Paulalso worked closely with ourDepartments of Justice and Stateregulators to explain our commitmentto, and progress under, the DPA andConsent Agreement. Paul effectivelywon the regulators’ trust and respect.A Department of Justice statement inits motion to dismiss the UTC DPAsums up nicely the results of Paul’sleadership:

Export Control Practitioner of the Year

Paul Beach

‘His legacy speaks for itself and his name should

be added to the export control “hall of fame”!’



“From top to bottom, the UTC

Entities responded to the case and the

resulting monitorship with

remarkable transparency,

professionalism, cooperation and

care…While following the UTC

Entities’ compliance with the DPA

over the past two years, it became

readily apparent to the Office that the

UTC Entities intended not just to

meet the terms of the DPA but to

exceed them in a genuine and good-

faith pursuit of a robust trade and

export compliance program. UTC’s

work, and the work of the

independent monitor not only met –

but exceeded – the Office’s

expectations under the DPA.”

As UTC now continues its workunder the Department of StateConsent Agreement, we are confidentthat with the strong ITC programfoundation Paul envisioned and

created, we are well on our way to ourgoal of achieving sustainable world-class excellence in all aspects of tradecompliance. The quality of ourprogram and the overall progress wehave made would simply not havebeen possible without Paul’sleadership, practitioner excellence,tireless drive, and commitment to thecompliance mission.’

If our awards are to ‘recogniseoutstanding work, vision, bestpractice, commercial benefit to thecompany, and contribution tointernational security,’ Paul Beach isundoubtedly a very worthy winner.

Runner-Up: Beth Peters,Hogan Lovells

Beth Peters is the Co-Practice Leaderof Hogan Lovells’ International Tradeand Investment practice. She has over25 years of experience advising clientson the full range of international tradematters, including export controllaws, sanctions laws, customs laws,anti-boycott laws, anti-moneylaundering laws, and the U.S. PatriotAct.

As she has for many years – and inaddition to providing policy advice,leading global investigations andenforcement matters, and helpingclients obtain critical regulatoryapprovals – in the past 12 monthsPeters counselled clients from a rangeof industry sectors, from cruiseoperators to universities, global mediagiants to international pharmas. Sheis a key lawyer in the representationof two companies seeking removalfrom the U.S. Entity List; the leadlawyer who sought approval of theU.S. government for Carnival CruiseLines regarding vessel and serviceoperations in Cuba and for STARRCompanies’ aircraft and travelactivities to Cuba; joint counsel totwo of the largest media companies in

the world, advising both companies ofthe applicability of U.S. sanctions,export controls, and anti-boycottregulation; lead trade lawyer for aprominent social media company,addressing export control andsanctions licensing and compliance,including with respect to software;advisor to a major universityregarding an export enforcementaction, including obtaining afavourable advisory opinion regardingpublished software.

Highly commended

Jeannette Chu is ManagingDirector, Export Controls and TradeSanctions, at PricewaterhouseCoopersAdvisory Services LLC in the U.S.Prior to joining PwC, she served as aSenior Policy Advisor at the Bureau ofIndustry and Security and was theprincipal advisor to the AssistantSecretary for Export Administrationon foreign policy issues includingbilateral and multilateral cooperationon export controls. She worked on theearliest stages of the Export ControlReform effort and reviewedrecommendations from industry. Shenotes: ‘At one point I haddeconstructed the entire CommerceControl List by ECCN, and had tapedup on the walls of my office pages ofspreadsheets, organised by category,noting reasons for control andavailable License Exceptions down tothe sub-para level.’

She is ‘passionate about buildingthe next generation of tradecompliance professionals and helpingeach one develop their strengths, findtheir niche. I believe knowledge thatis closely held risks being wastedwhilst sharing information creates“force multipliers” that truly helppractitioners serve their companiesand clients even better.’

Based in DC, Steptoe partner

Beth Peters

Peters was the lead lawyer who sought approval

of the U.S. government for Carnival Cruise Lines

regarding vessel and service operations in Cuba

and for STARR Companies’ aircraft and travel

activities to Cuba.

Judging panel and process

All submissions were reviewed by the

WorldECR team and a shortlist then

prepared for each award which was

given to our judging panel to make their

decisions upon. Judges were asked to

review the shortlists and choose a

winner and runner-up for each category

(excluding Export Controls Compliance

Team of the Year, Rest of the World).

Judges were given total freedom as to

how to prioritise the various

achievements of shortlisted individuals

and organisations in coming to their

decisions. Judges associated with a

shortlisted organisation were deemed

conflicted and unable to vote in that

category. Where the judges’ decisions

resulted in a tie, the casting vote would

be that of the WorldECR team.

The WorldECR team included Tom Blass,

editor, and Mark Cusick, publisher. Our

judging panel were: Carol Fuchs,

General Electric, Executive Trade

Counsel (retired); Ralf Wirtz, Head of

Group Trade Control, Oerlikon; Ian J.

Stewart, Head, Project Alpha, King's

College London; Jay Nash, Managing

Director, Strategy & Development,

Securus Strategic Trade Solutions;

Lourdes Catrain, Partner, Hogan Lovells;

Bill McGlone, Partner, Latham &

Watkins; Michael Burton, Partner,

Jacobson Burton Kelley PLLC;

Konstantinos Adamantopoulos, Partner,

KA Legal; Nick Boland, Director of

Solutions Consulting, EMEA, Amber

Road.


Winner: Anahita Thoms,Freshfields BruckhausDeringer

Our Young Practitioner of the Yearhas demonstrated both technicalexpertise and a desire to make adifference. Anahita Thoms is acounsel in Freshfields’ disputeresolution practice and the New YorkGroup Leader for the firm’s GlobalSanctions and Trade group. Shefocuses her practice on globalinvestigations, in particular in thefield of international trade law,including sanctions and exportcontrol, and data protection law.

In a year of growing interest in thebusiness opportunities possible inIran, being Iranian born and able tospeak Farsi has proven useful forThoms: from identifying Iranian localcounsel, dealing with Iranian advisoryfirms, questioning the structural set-up of companies, and putting thingsinto perspective when culturaldifferences seem to become anobstacle.

Away from Iran, she advised

l a Japanese company on theimplications of the Ukraine andRussia sanctions;

l a multinational undertaking withregard to investigations in relationto exports to Russia and Thailand;

l a multinational company on

criminal proceedings in relation toexport control violations;

l a Swiss bank with regard to thecompliance of finance contractsunder the EU Iran and Libyasanctions.

A contemporary at a DC law firmcomments: ‘I would not entrust asingle client to anyone but AnahitaThoms, when it comes to seekingdependable expert advice and acumenon export controls, in particularcompliance programs, accompanyingglobal internal and externalinvestigations and self-disclosures.’

Recognition of her abilities appearswidespread: after serving three yearsas a Vice-Chair of the American BarAssociation Export Controls andEconomic Sanctions Committee, shehas now been elected Chair – she willbe the first non-American in theposition.

She is a founder member of UnitedAgainst Modern Slavery. Describingthe initiative, she says it ‘supports andadds value to the work of the manyNGOs, UN organisations and charitiesthat are combatting modern slavery.United Against Modern Slavery givesindividuals, charities andorganisations a platform to amplifytheir voice.’

Runner-Up: RebeccaAntzoulatos, Bureau ofInternational Security andNonproliferation

Rebecca Antzoulatos works for theBureau of International Security andNonproliferation, Office of ExportControl Cooperation (ISN/ECC) andis based in Washington, DC. Rebeccamanages the U.S. government’sExport Control and Related Border

Young Practitioner of the Year

Anahita Thoms

‘After serving three years as a Vice-Chair of the

American Bar Association Export Controls and

Economic Sanctions Committee, she has now

been elected Chair – she will be the first non-

American in the position.

Meredith Rathbone assists clientsin the financial services, technology,telecommunications, energy, defence,insurance, manufacturing, retail, andservice industries, among others. Sheserves on the U.S. State Department’sAdvisory Committee on InternationalEconomic Policy’s SanctionsSubcommittee, and is immediate pastco-chair of the American BarAssociation’s Export Controls andEconomic Sanctions Committee of theInternational Law Section.

In the past year, she hasrepresented the Coalition forResponsible Cybersecurity in itsefforts to challenge the proposedintroduction into the U.S. ofWassenaar Arrangement intrusion

software controls, presenting on thetopic at numerous BIS TechnicalAdvisory Committee meetings. Theseefforts resulted in the U.S.government agreeing to seekrenegotiation of the rule with otherWassenaar Arrangement members in2016. Rathbone continues to workwith the Coalition to achieve anacceptable outcome in the ongoinginternational debate.

Stephen Propst, a partner inHogan Lovells’ Washington, DCoffice, helps clients navigate complexissues under U.S. export control andeconomic sanctions regulations. In2011, his paper, released at a forum atThe Brookings Institution andpresented to senior government

officials, provided the legal analysissupporting President Obama'shistoric changes to the U.S. embargoagainst Cuba, announced inDecember 2014. In December 2015, afollow-up paper analysed additionalchanges that the Administration couldmake under executive authority tofurther ease the U.S. sanctions andexport controls applicable to Cuba.Virtually all of the potential regulatorychanges identified therein have nowbeen implemented through formalregulatory amendments. Seniorgovernment officials have confirmedthat these papers were widelyreviewed and consulted within theAdministration to support thechanges in 2015 and 2016.




Security (‘EXBS’) programme forSouth East Asia, which includesdeveloping, implementing, managingand coordinating in key countries U.S.government export and border controlassistance programmes designed tohelp establish and strengthencomprehensive national exportcontrol systems and responsibleexport control policies to stem theproliferation of weapons of massdestruction, their delivery systems,and conventional weapons.

Rebecca has played a key role inbringing through the signing into lawby the President of the Philippines ofa Strategic Trade Control (‘STC’) law.As the EXBS Program Manager,Rebecca ‘spearheaded the U.S. effortsto assist the Philippines to adopt aStrategic Trade Management Act(STMA) that reflected the latestinternational norms’. Along with theEXBS advisor and EXBS legal team,Rebecca worked with the Philippinesgovernment representatives ‘tofinalise the draft STMA and theimplementing rules and regulations’.

Jason Witow, Director of the Officeof Export Control Cooperation, iseffusive in his endorsement ofRebecca’s achievements andapproach: ‘Rebecca is theconsummate export controlsprofessional. Her strong strategictrade expertise and hard work havemoved the countries in her portfolioto make considerable advances intheir strategic trade control programs.Her ability to synthesise her ownknowledge with reports from the fieldand to work collaboratively with anentire team of people are among thequalities that have helped hersucceed. Added to that is herpersistence, which alone wasresponsible for pushing the Philippinegovernment to pass strategic trademanagement legislation. Rebecca has

already achieved a great deal inworking with her countries, and weare all the more secure for it.’

Highly commended

Alicia Neubig is an associate inLatham & Watkins’ Washington, D.C.office. She focuses her practice in theareas of export controls, economicsanctions, customs, and anti-corruption. Alicia works regularlywith companies across a wide range ofindustries, including pharmaceutical,aerospace, defence, and oil and gassectors. She has assisted and advisedclients on complex internalinvestigations and enforcementmatters across multiple jurisdictions.

In addition to advising commercialclients, Alicia works extensively withpro bono clients, including CAREUSA, the International Committee ofthe Red Cross, and MercyCorps, thatprovide humanitarian relief incountries subject to U.S. and EUeconomic sanctions and stringentexport control laws. For example,Alicia has used her export controlsand sanctions experience andknowledge to help these organisationsnavigate and overcome crucialbarriers to providing emergency reliefin Syria, such as helping securelicensing from the U.S. Commerce

Department to take into Syria U.S.-regulated goods, including cellphones, satellite phones, and GPSdevices, that are essential forhumanitarian workers to deliver aidsafely and effectively.

Alicia has also helpedorganisations address regulatory andlicensing challenges by advocating forfavourable regulatory interpretationsthrough interpretive ruling requeststo the U.S. Treasury Department’sOffice of Foreign Assets Control andmeeting with officials from the U.S.departments of Commerce and Stateto explore proactive, long-termlicensing solutions.

Clients have consistently expressedtheir gratitude for Alicia’s work.Earlier this year, CARE’s GeneralCounsel requested that Alicia travel toJordan to offer training andcompliance guidance to staff fromCARE’s offices in Jordan, Turkey, andLebanon, all of whom are on thefrontlines of the Syria crisis. Aliciawas delighted to do so.

Brian Byrne is the leadingassociate in international law firmBakers Botts’ EU sanctions team. Headvises on all aspects of the EUsanctions regime. He has amassed alevel of experience, client contactsand expertise in relation to EUsanctions that is exceptional for alawyer of his age (30). Indeed, Brian’s

Rebecca Antzoulatos

As the EXBS Program Manager,

Rebecca ‘spearheaded the U.S.

efforts to assist the Philippines to

adopt a Strategic Trade Management

Act (STMA) that reflected the latest

international norms’.


reputation has led to his beingappointed as a guest lecturer, in EUsanctions, at Ireland’s leading lawschool, the Sutherland School of Lawat University College Dublin.

Over the past 12 months, Brian hashas acted as one of the first points ofcontact for a number of global nameRussian clients in the energy andfinance sectors, advising them onsanctions imposed by the EU againstRussia.

He has advised on the impact ofEU sanctions on contemplatedtransactions, carried out detailed riskassessments, and drafted contractualprovisions to reflect the relevantimpact of economic sanctions. He hasalso advised on a number of highlycomplex financing structures. Brianalso manages a team of lawyers whomonitor and produce a daily reportfor a client, setting out all relevantdevelopments regarding EU sanctionsinvolving Russia and any related EUpolitical activity.

Alongside his busy practiceadvising Russian clients, Brian hasbeen busy on Iran-related matters; forexample, carrying out detailed riskassessments for a globalpharmaceutical company related to

activities involving Iran and advisinga major manufacturer in relation tosales and payments (made inaccordance with EU law) running totens of millions of dollars to countriestargeted by EU sanctions, includingIran.

Dj Wolff is a counsel in Crowell &Moring’s Washington, D.C. office anda consultant with C&M International,the firm’s trade policy affiliate. Hispractice covers compliance with U.S.economic sanctions, export controlsand antiboycott regimes, and anti-money laundering (‘AML’) laws andregulations.

Despite his youth, he has alreadymade a mark – one client reports:‘Having engaged him many times as aclient, I have sufficient experience tosay that he is now our go-to counselfor trade sanctions issues. I wasinitially reluctant to rely on DJbecause of his relatively few years ofexperience – until the partner wenormally deal with was away. Fromthat interaction, we were incrediblyimpressed. He is prompt, responsive,supremely competent... He is sojarringly knowledgeable about allfacets of international trade issues,particularly about our industry, that

we can often solve problems in justminutes.’

During the past year, Dj has,among other instructions:

l Collaborated with U.S. and EUdata privacy colleagues torepresent a non-U.S. subsidiary ofa U.S. financial institution in apetition to the French Data Privacyauthority for authorisation toconduct screening for sanctionscompliance against certain types ofpersonal identifying information.

l Provided guidance to a non-U.S.financial institution on the scope ofdebt and equity restrictions underU.S. sectoral sanctions applicableto Russia.

l Conducted due diligence on apotential target company’scompliance with U.S. economicsanctions and export controls onbehalf of a U.S. private equity firmin a successful $1.4bn acquisition.

l Represented a U.S. manufacturerin negotiations with the Bureau ofIndustry and Security and Customsand Border Protection to securerelease of oil and gas equipmentimproperly seized before export toRussia.

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Winner: Steptoe

There is no change at the top in thiscategory from last year, Steptoe andHogan Lovells securing the honoursonce again.

Steptoe’s DC office is home tosome of the country’s most highlyregarded lawyers and their workcommands respect throughout theexport compliance community. EdKrauland leads the team, while fellowpartner Meredith Rathbone wasactive in one of the highest profileexport control matters in the U.S. inthe past 12 months, advising theCoalition for ResponsibleCybersecurity on its response to theproposed introduction of theWassenaar intrusion software/surveillance controls into the U.S.(see below). Highlights for the teamhave included:

l Advising the Coalition forResponsible Cybersecurity, whichrepresents a broad cross-section ofU.S.-based cybersecuritycompanies, including Symantec,Ionic Security, Intel, Microsoft,FireEye, and Raytheon. In 2015-2016, Steptoe was at the forefrontof the Coalition’s efforts to educateU.S. and non-U.S. policymakers onwhat were felt to be the harmfuleffects of the WassenaarArrangement’s rules on so-calledintrusion software, includingcomments on the proposed rule,presentations at numerous BISTechnical Advisory Committeemeetings, and congressionaloutreach. These efforts culminatedin the U.S. government agreeing toseek renegotiation of the rule withother Wassenaar Arrangementmembers in 2016.

l Advice to a major aerospace clienton its corporate and contractualexpansion into the internationalmarket for unmanned aerialsystems falling within Category Iand Category II of the MissileTechnology Control Regime. Theassistance related to classificationassessment, advice on establishingsubsidiary operations abroad, andsales into the Middle East region,and U.S. government licensingstrategies.

Runner-Up: Hogan Lovells

Hogan Lovells is a major force intrade compliance, with a client basethat straddles the globe and industry,and includes: 21st Century Fox,Accenture, Airbus, Amazon, AppleLeisure Group, Barclays, CarnivalCruise Lines, Celgene, Chubb, Ciena,Citibank, IBM, ICF International,Intelsat, Johnson & Johnson,Mitsubishi Nuclear Energy Services,News Corporation… as well as variousacademic institutions, which the teamhas advised on ‘complex issues relatedto export controls and fundamentalresearch’.

Beth Peters leads a large, strongteam which is also home to, amongothers, highly respected partnersStephen Propst and AjayKuntamukkala.

Among instructions last year, theteam advised a leading Internetcompany on a range of export controlissues critical to the globaldeployment of the company’sconnectivity technologies, cloudcomputing, and encryption; and itadvised Alcatel-Lucent regarding U.S.export control issues in connectionwith the U.S.$17 billion sale ofAlcatel-Lucent to Nokia, preparingnumerous filings and notifications tothe departments of Commerce andState.

Highly commended

Baker & McKenzie: Often calledthe world’s first global law firm, Baker& McKenzie has a very well respectedU.S. export controls practice acrossthe country.

On the West Coast, San-Francisco-based partner, John McKenzie has

been busy advising clients in thesemi-conductor industry, while in DC,former firm Chairman, Nick Cowardis the best-known of an especiallystrong team, which includes, amongothers, Janet Kim and Sylwia Lis.

Recent work has seen the firmrepresent a major packagingmanufacturer in a variety of exportcontrol and trade sanctions matters,including representation before theU.S. Treasury and Commercedepartments in voluntary disclosures,conducting an internal export controlcompliance assessment, and advisingon export control and trade sanctionscompliance issues in the context ofproposed transactions.

Page Fura is a two-partnerboutique trade law firmheadquartered in Chicago. Whilst thefirm will never compete with the likesof Hogan Lovells and Baker &McKenzie for the largest clients andinternational coverage, itscontribution to its clients’ commercialinterests is to be commended: ‘Thework we do is – on occasion –glamorous but more often than not itis the type of roll-up-the-sleeves laborwhose reward is realised through theprotection of our clients' interests andthe preservation of their compliancerecord in the face of governmentchallenge.’

A recent instruction saw one of thefirm’s client's ‘involvement in a formalinvestigation of its unrelated MiddleEast distributor who had initiallydeclined to provide access to regionalOffice of Export Enforcement (“OEE”)representatives who were conductingend-user verifications. As a result ofthat intransigence, our client'sshipments to that distributor weredetained at the U.S. Port of Exportand we were required to broker a

Export Controls Law Firm of the year, U.S.A.

Edward Krauland and Meredith

Rathbone, Steptoe

The firm offers a multi-jurisdictional

export controls advisory service,

characterised by ‘practical advice

that takes into account the needs of

business; quick response times’ and

expertise throughout the ranks of

associates, counsel, and partners.’




resolution to the logjam by forcing thedistributor to re-engage with OEE,negotiating with OEE to prioritise areturn meeting to perform the end-user verification, working with localport officials to secure the release of

all detained shipments andsupporting in-house counsel inmanaging the expectations of seniorleadership regarding the timing andpotential outcome of theinvestigation. In the end, despite

shipment and order fulfillmentdelays, we were successful atretaining our client’s businessrelationships while also creating apositive impression of our clientbefore OEE.’

Winner: Baker & McKenzie

Hopping across the Pond, the winnerin this category in 2016 is Baker &

McKenzie. The export controls teamis spread across the continent, withexpert practitioners in Amsterdam,Frankfurt, London, Brussels, Zürich,Barcelona, Stockholm, Rome,Moscow, Paris, Warsaw andBudapest. Well-known lawyersinclude Mattias Hedwall (Stockholm),Jasper Helder (Amsterdam) and RossDenton (London), along with regularWorldECR contributor Philippe Reich(Zurich).

The team is always busy, providingthe full range of export compliance-related legal services – licensing;transaction-specific risk assessment(helping companies assesscompliance risks and determineregulatory requirements triggered byspecific transactions and businessrelationships); due diligence incorporate transactions; reviewing andimplementing complianceprogrammes and training;investigations and enforcement;legislative/regulatory advocacy; andinteraction with regulators.

A spokesperson for the firm says:‘Unlike many other law firmspractising in the areas of exportcontrols, trade sanctions, andantiboycott laws and regulations, theattorneys in our trade compliancegroup are not “general” tradepractitioners but instead specialise inthese specific regulatory areas. Theywork in these areas on a daily basisand have developed long-termrelationships with the governmentagencies before which they representtheir clients’ interests, including inter

alia Germany’s BAFA, Switzerland’sSECO, the Netherlands’ CDIU, TeamPOSS and Ministry of Foreign Affairs,France’s SBDU and the UK’s ECO.’

Among a long and diverse list ofengagements in the past year were:

l Advising a defence contractor onthe acquisition of L-159 aircraftsfrom the Czech Ministry ofDefence. The team advised on legalaspects of the acquisition,including export control approvalsconnected with the militaryequipment, regulatory andsanctions aspects, as well asseeking export permits from thirdgovernments.

l Advising a listed Switzerland-based international tech companyon setting up and implementing aglobal export control and sanctionspolicy and representing it beforethe Swiss authorities to regulariseexports of special military goods.

l Carrying out an internalinvestigation on behalf of a globalclient in the nuclear industry inrelation to a transfer of controlleddual-use nuclear technologywithout the necessary exportlicence. The team then preparedand submitted a voluntarydisclosure to the UK’s HMRCbased on the findings of theinvestigation.

Runner-Up: Holman FenwickWillan

Last year’s bride is this year’s maid ofhonour. Holman Fenwick Willan

focuses on serving clients in thecommodities, mining, energy,

shipping, aviation and insurancesectors. Key contacts are partnersAnthony Woolich and Daniel Martinin the London office.

In the past year, the team

l Coordinated advice across a largenumber of jurisdictions worldwide(including countries in Asia, SouthAmerica and Europe) on theimpact of export controls onmultiple cross-border helicoptertransactions (the client is a globalindependent helicopter leasingcompany, with a fleet of over 100aircraft on lease in numerouslocations worldwide);

l Advised an international seller oftelephone handsets on EUencryption controls;

l Assisted a global shipowner andoperator with a fleet of almost 500container ships to develop systemsfor automated screening of cargoescarried on board their ships toidentify (and reject) any controlledgoods, by producing a database ofcontrolled goods, by reference toHS codes and targeted keywords.

Highly commended

GvW Graf von Wesphalen’ssanctions and export control team,which is based in Hamburg,Düsseldorf and Brussels, currentlyconsists of three partners, one of-

Export Controls Law Firm of the year, Europe

Mattias Hedwall leads Baker & McKenzie’s Global

Trade & Commerce Group

The team is known for its ‘Pan-European trade practice

which advises substantial multinational clients on a

diverse range of trade matters including the effect of

export control and sanctions regimes as well as

customs law and product classification.’



counsel and four associates. It is ledby Dr. Lothar Harings, MarianNiestedt and Dr. Gerd Schwendingerout of Hamburg and Brussels. Theteam is well known, presentingregularly at conferences andcontributing articles on developmentsin German and EU regulation.

An interesting instruction in thelast year saw the team represent aleading German mechanicalengineering company before theGerman Federal Office of Economicsand Export Control (‘BAFA’) and theAdministrative Court in a caserelating to the export of machinery forthe oil and gas industry to Iran. BAFA

was of the opinion that the export wasprohibited under current controls andGvW brought an action in theAdministrative Court to oblige BAFAto issue an export licence. The firmsought an oral hearing with the judgeand obtained a decision for the clientin an usually short period of time infavour of the client, obliging BAFA toissue the export licence.

Also highly commended is theEuropean team at Hogan Lovells.When the Belgian customs prosecutorinvestigated a Belgian subsidiary of aFortune 100 company regarding anunauthorised export of a dual-useitem from the EU, Hogan Lovells

helped the company to investigateand identify the glitch, includingreviewing its European supply chainand associated trade compliancefunction in the wake of a recentbusiness restructuring. The firmrepresented the company in front ofthe Belgian export control authorities,and worked with it to establish newworking processes to avoid similarproblems in future. Additionally, thefirm provided advice on exportcontrols and helped coordinateRomanian and Bulgarian regulatoryinput in the February 2016 merger ofa leading satellite operator and adigital media services provider.

Winner: Economic LawsPractice

The Indian export control regime is farfrom transparent and great experienceis needed to navigate it. Sanjay Notani,a partner of Economic Laws Practice(‘ELP’) and lead contact, is well knowninternationally as being a leadingnavigator for the journey. A familiarface at events outside the sub-continent, Notani is very much seen asthe ‘go-to’ man for questions on Indianexport controls.

‘Hands-down the best in India,’ isone glowing testimonial. ‘They [ELP]work with almost anyone/everyonewho deals in controlled sectors inIndia, one of the most criticalcountries/economies in the worldtoday, they are unique is being both a“local” and such a globally-knownspecialised firm in this field.’

ELP’s work in export control andsanctions typically includes:

l Advice on controlling regulationsand compliance procedures;

l Assistance with drafting, filing andapplications for licences;

l Assistance with applying for andobtaining export licences, whererequired, from the various licensingauthorities;

l Reviews of business operations andtransactions to identify risk areas;

l Advice and assistance on policyinitiatives and representationsbefore governmental authorities.

Recent instructions for the firmhave seen it represent a leadingmultinational in a matter arising out ofthe export of valves manufactured inIndia ‘against a background of someincongruity’ in the particular SCOMET(list of controlled items) entry. Thefirm approached the DirectorateGeneral of Foreign Trade, seeking anamendment to the relevant entry, theresult being that the entry wasamended to remove the incongruityand to ensure a level playing field todomestic players in the internationalmarket.

Another instruction saw it provide adetailed review of the entire operationsand activities of a leading pharma,identifying the export regulationsrequiring compliance, coupled with acomprehensive risk assessment ofexisting processes and practices andpreparation of a standard operatingprocedure which could be used by thecompany for future risk assessmentand related compliances.

Runner-Up: McCarthyTétrault

The International Trade andInvestment Law Group at Canadianlaw firm McCarthy Tétrault is led byJohn Boscariol and Robert Glasgow inthe Toronto office and Simon Potter inMontreal. Boscariol is particularly wellknown internationally, regularlygarnering glowing reviews in thevarious legal directories. The team actsfor clients from a wide range ofindustry sectors.

Recent instructions have included:

l Acting for Expobank of Russia in a(rare) successful de-listing fromCanada’s schedule of designatedpersons (equivalent to U.S. SDNs)under the country’s economicsanctions against Russia;

l Acting for a transportationcompany on a major internalinvestigation into economicsanctions compliance in respect of

Export Controls/Sanctions Law Firm of the year,

Rest of the World

Sanjay Notani, Economic Laws Practice

Notani is well known and regarded by

international trade practitioners. His expertise is

in advising on import and export control as well

as on licensing issues, with particular focus on

regulations controlling dual-use goods and

technologies.



John Boscariol, McCarthy Tétrault

Boscariol is well known internationally. He is

Co-Chair of the Export Committee of the

Canadian Association of Importers and

Exporters and currently sits on the Industry

Engagement Committee of Public Works and

Government Services Canada for the

administration of Defence Production Act and

Controlled Goods Program.

its activities in Canada and theUnited States;

l Acting for two network securitycompanies on internal investigat -ions and preparation of voluntarydisclosures to the Canadianauthorities regarding cryptographicexport control violations;

l Acting as expert witness for aCanadian defence manufacturerdefending claims of human rightsand employee discrimination inenforcement of U.S. ITAR andCanadian defence trade controls.

Highly commended

With a truly global practice, Baker &

McKenzie boasts top-notch exportcontrols practitioners around theworld. Eugene Lim (Singapore) andEsteban Ropolo (Buenos Aires) areamong a group of highly regardedlawyers.

Recent instructions have seen thefirm

l Advising a multinational corp -oration that specialises in energymanagement regarding exportcontrols applicable to new productsand technologies across the AsiaPacific region. The project required

the team to collaborate with counselin multiple jurisdictions.

l Advising a multinational financialinstitution on the classification ofthousands of its fintech softwareapplications under Singaporeexport control rules as part of itsinternal export control compliancereview process.

l Advising an Argentine oil and gassupplies manufacturer in aninvestigation initiated by the U.S.authorities against one of thecompany’s U.S. suppliers.

Lawyers in Hogan Lovells’

Beijing office work closely with theirDC counterparts on matters arisingout of U.S.-China trade andinvestment. Clients, who are active

across a wide range of industry sectors,including medical devices, technologyand social media, benefit from theteam’s expertise in trade andencryption controls.

The Beijing office advised a globaltechnology company on exportcontrols and economic sanctions aspart of a global trade compliance risk-assessment project, including a reviewof the export control and economicsanctions laws in China. The team alsoadvised the client on regulatoryrequirements for the use andimportation of encryption software,and assisted in applying for andobtaining the Chinese encryptionauthority’s permits for the import anduse of various encryption softwareproducts into China.

Winner: BAE Systems plc

BAE Systems is a global defence,aerospace and security company withmore than 80,000 employeesworldwide, customers in more than 80countries and annual sales of near £20billion. The non-U.S. BAE Systemsexport control function comprisesapproximately 150 full-time and nearly900 part-time personnel. The functionis led by a Group Export Control(‘GEC’) team of 10, based outsideLondon and containing lawyers, exportcontrol specialists, compliance officers,training leads and project managers.

Joshua Fitzhugh is Group Head ofExport Controls and based in the UK.He speaks about a sea change in thecompany’s approach to compliance:‘Over the past five years, the UK-managed portions of BAE Systemshave revolutionised the way weapproach export control compliance.

We have transformed from a small,decentralised group of ad hocpractitioners with little in the way offormal procedure and process into afull-fledged corporate function with adefined mission, a robust proceduralframework and a world class functionalcapability.’

The revolution in approach neededa new mindset as well as newprocedures. ‘The company embraced a

culture of compliance,’ says Fitzhugh,‘adopted a new Export Control Policyand 12 Export Control Procedures,each addressing a different aspect ofexport control compliance. Thebusinesses and functions reflected therequirements of these group-levelprocedures in hundreds or thousandsof new business-level procedures,processes and work instructions, andhave worked diligently to embed those

Export Controls Compliance team of the year, Europe

Joshua D. Fitzhugh, Group Head of Export

Controls

‘We have transformed from a small,

decentralised group of ad hoc practitioners with

little in the way of formal procedure and process

into a full-fledged corporate function with a

defined mission, a robust procedural framework

and a world class functional capability.’



requirements into their day-to-dayactivities.’

Creating a wider culture ofcompliance involves communicationand knowledge sharing. According toFitzhugh, the company has supportedthis in enabling the export controlfunction to maintain:

l An Export Control FunctionalCouncil to discuss core issuesamongst the functional leadership;

l A Functional Resource Review todirect recruitment, career progress -ion, retention and succession withinthe function;

l An Export Control Working Groupto coordinate functional issuesbetween GEC and the non-U.S.businesses;

l A Risk Committee to analyse, trackand consolidate the reporting ofexport control risk across the non-U.S. businesses;

l A Corrective Actions and LessonsLearnt Working Group to discusstrends, lessons learnt, and bestpractices in investigating, disclosingand remediating export controlviolations;

l A Licensing Working Group toshare licensing best practicebetween GEC and the non-U.S.businesses;

l A Learning and DevelopmentWorking Group to collaborate onexport control training developmentfor the non-U.S. businesses;

l A UK Controls Working Group todiscuss trends and share bestpractice in UK export controlsbetween the non-U.S. businessesand GEC;

l An Information Management andTechnology Community of Practice,currently subsumed within a group-wide export control automationinitiative, to share best practice andalign IT enablement across the non-US group; and

l A Suppliers Working Group to sharebest practice and coordinatebetween BAE Systems and itssuppliers, commercial partners andindustry peers on export controlissues of mutual interest.

There will be many positivecommercial consequences arising fromthis internal revolution, and few will beas noteworthy as, in Fitzhugh’s words,‘Our breach statistics have improveddramatically as we have improved our

approach to export control compliance.In 2012 our voluntary disclosurenumbers increased dramatically, asone would expect for a company of oursize newly under a State Departmentconsent agreement. By 2015, as ournew procedures and process were fullyembedded within our non-U.S.businesses, the overall volume ofbreaches had dropped byapproximately 400%... These dramaticdeclines in overall breaches flowdirectly from the success we have hadas a function in embedding theprincipals of export control complianceacross the company.’

We congratulate the company on itsachievement.

Runner-Up: Marshall ADG

It’s always good to receive greatfeedback from your client, even – orespecially – when that’s the parentcompany you are keeping compliant.

‘In my position of Commercial andProcurement Director having aknowledgeable and competent tradecontrol team is of course a necessityand “a given”. Our Group TradeControl team not only has thoseabilities but in addition to this, they arepassionate and care immensely aboutwhat they do. One of theirresponsibilities is to act as the Group ‘s“conscience”, especially when dealingwith strategic sensitive projects; I ampleased to say that they have alwaysfulfilled this responsibility very well;which in my role is much reassuring.’

So wrote Ian Atkinson, VPCommercial & Purchasing, at MarshallAerospace and Defence Group. TheTrade Control Team, led by LaurenceCarey, may be a fraction of the size ofthat at BAE, but it is also clearly doingits job and more. Carey, herself, talksabout the passion that her small teambrings to the job. It has kept themgoing during some tough challenges.‘After many years of looking solely after

its UK Aerospace business,’ says Carey,‘the team, two members at the time(Carey, herself, and Trade ControlOfficer, Anna Dziuba) was facing thefollowing challenge: the total volume oftrade control activities did not warrantthe recruitment of specialists for everyentity, however for the team to handleall day-to-day activities across thegroup, especially remotely, would havepotentially compromised compliance.An innovative approach developed tomake the most of its resources whileensuring compliance and enablingbusiness for all its entities wasadopted:

l Recognising the shortage ofexperienced trade controlspecialists, a law graduate (EleanorWynne) with an interest in tradecontrols was recruited and putthrough an intense hands-ontraining and developmentprogramme; and

l By leveraging “champions” at eachlocation, the team created the rolesof “Company Export Control Focal”and of “Project Export ControlFocals”. The individuals selected tofulfil these roles have to meetcertain competencies, they receiveexternal and internal training. Theyact as the “eyes and ears” of theTrade Control team.

The team is, says Carey, ‘hands-on’and ‘solutions-driven’: ‘Working withcolleagues on alternative compliantsolutions that are acceptable to thebusiness requires a considerableinvestment of time and efforts. Whileit would be easier to adopt a “No”approach, the team never succumbsunder the temptation.’

Marshall ADG has over 2,300employees globally, with mostemployees based in the UK and the restin Canada, Australia and theNetherlands. Its annual sales figure for2014 was £307m. There’s a lot of salesand transfers to keep the team busy. To

Laurence Carey, Group Trade Control Manager,

Marshall Aerospace and Defence Group (ADG)

The team’s mission statement is ‘Facilitating Compliant

Business. This captures two key ideas: (i) we need to

support our business to act in compliance with laws and

regulations, but (ii) we also need to help the organisation to

do business.’



sustain compliance throughout thebusiness, says Carey, ‘the team mustshow constant determination andflexibility, be commercially aware, ableto negotiate contractual trade controlterms, have in-depth knowledge oftrade control laws and regulations,deliver training, draft processes, andcarry out audits.’

Carey considers their work in thecontext of a bigger picture: ‘Oneimportant objective for the team is tocontribute towards internationalsecurity: with the group’s increasinginvolvement in complex internationalsupply chains, involving newgeographical markets, the teamensures that all employees are aware ofthe risks of diversions, of the need fortighter checks’ and will also look toeducate third-party business partners.

Highly commended

Saab AB has ‘a terrific philosophytoward compliance,’ say one well-known export compliance consultant.The company ‘works with the Swedishgovernment to help promotecompliance among their partners andtheir personnel are present atconferences all over the globe.’

Bjorn Uggla has been Group LegalAffairs Vice President and Head ofExport Compliance at Saab AB (publ.)since 2014. He has overallresponsibility for export compliance atthe company. He says, ‘Our vision is:Export compliance, securing ourprivilege to export. And our mission is:

By complying with all export controllaws, regulations and authorisationsand having an outstanding trackrecord as well as continuouslyimproving ourselves, we secure ourright to do business on a highlyregulated market.’

Every Saab Group business area(‘BA’) has an Export Control Teamheaded by an Export Control Director(‘ECD’) who is responsible for exportcontrol within the BA. In total, theteam consists of around 30 peopleacross the different business areas. Allthe ECDs are members of Uggla’sExport Control Council, where policyand directives are discussed as well asoperational issues. The Council meetson a monthly basis and is apreparatory and advisory forum fordecision making on:

l Policy, strategy, planning andtraining

l Laws and regulationsl Certificationl Monitoring and controll Process, Methods and Tools

The company is committed to

improving efficiency via technology:‘As a global company we have a lot ofchallenges to cope with when it comesto export control compliance and weare introducing more and more ITtools to help, together with a focus ontraining. The IT tools help us take careof all classification information,authorisations and to handlecontrolled technical information whenit comes to access and transfer withautomatic logging.’

The corporate team travelsregularly, conducting training andexport compliance audits. Indeed,training is paramount. Uggla notes:‘When it comes to human resourcesevery employee working full time withexport control is certified by theSwedish Export Control Society.’

He sees the company’s widercontribution to security key: ‘Outreachis an important part of my job and I’msupportive of the society as well as theSwedish Export Control Authority(ISP) who provide teacher resources tothe Society’s yearly educationprograme. Today two persons from thecompany are members of the steeringboard of the Society.’

Bjorn Uggla, Group Legal Affairs Vice President and

Head of Export Compliance at Saab AB (publ.)

‘Our mission is: By complying with all export control laws,

regulations and authorisations and having an outstanding

track record as well as continuously improving ourselves,

we secure our right to do business on a highly regulated

market.’

Export Controls Compliance team of the year, U.S.A.

Winner: RockwellAutomation

‘Rockwell Automation have a

committed approach to truly global

export control compliance with high-

calibre and knowledgeable teams

and personnel across the globe, also

working to help promote trade

compliance locally among Wisconsin

companies.’

International consultant

Nathan Eilers leads the Global TradeCompliance (‘GTC’) team at RockwellAutomation, the world's largest

company dedicated to industrialautomation and information.

Part of the Office of GeneralCounsel, the GTC team supports allbusiness units and subsidiaries

globally on all import, export controls,sanctions, and other internationaltrade compliance issues. In addition tooverall guidance and support,responsibilities include:



l Trade compliance policy imple -ment ation and oversight

l Trainingl Regulatory interpretation and

analysisl Audit and investigation, including

corrective action support andtracking

l Other activities as needed to ensurecompliance with applicable regulat -ory requirements

The GTC team works across allfunctions of the company to assess andimprove trade compliance to betterserve customers in 80-plus countries.The GTC team itself is relatively small– there are three senior tradecompliance subject matter experts onthe team (GTC managers), with analystpositions under two of them.Responsibilities are global and dividedby area: Import (Linda Zuehlke),Export (Dragan Ilic), andSystems/Audit (Mary JaneWildasinn). Dragan Ilic is the GlobalExport Trade Compliance Managerand has been in the role for more than15 years.

The GTC team owns and managesthe export controls programme andpolicy centrally. The team reviews andinterprets regulations, developsguidance, and trains stakeholdersglobally, working with RegionCompliance Managers (‘RCMs’) in thelogistics organisation to implementprocesses and execute much of theoperational activity associated withinternational trade controls.

Eilers sets out the team’s stall: ‘TheGTC team helps the company achievebusiness objectives in a manner thatensures compliance with applicableregulatory requirements. This meansproviding guidance in a clear andtimely manner, staying ahead ofregulatory changes, and workingcollaboratively with compliance andnon-compliance functions alike.Because it is a relatively small team,the ability to work across functionsand across the company is critical toour overall success in this area.’

According to Eilers, the team iscontinuoulsy looking at ways in whichit can improve its contribution to thecompany. ‘We’ve been instrumental inimplementing new tools toautomatically and seamlessly completeexport screening on software andfirmware downloads. We’ve enhancedour internal audit programme to cover

a much broader range of activities witha greater degree of granularity, boththrough on-site visits and via ourinternal systems. This has allowed usto continually improve and refine ourprocesses. We’ve also partnered withour internal audit team to incorporateimport/export compliance into theirstandard audits. We partner with theother internal compliance functions,chiefly those around product designand certification. As that body ofregulation continues to expandcomparable to export controls, we areable to share best practices,communication mechanisms, andtools. Our team created additionaltraining covering general awarenesstopics for import and exportcompliance, making it globallyavailable 24/7 through our SAPlearning platform. And we improvedour internal classification process withadditional checks during the productdevelopment process and a simpler,clearer set of questions for the productgroups to complete.’

Whilst during working hours, theteam provides training for employeesand shares knowledge of business-critical developments, outside thecompany, team members seek to sharetheir knowledge and experiences forthe greater good. According to Eilers,the team has ‘taken part in roundtablesthrough the World Trade Associationwhich is part of the local chamber ofcommerce. Anyone from the area withan interest in international trade iswelcome to attend. During [one]roundtable, the team led discussionson the Iran and Cuba sanctionschanges and export compliancescreening (know your customerquestions).’ Global import manager,Linda Zuehlke, has taughtimport/export compliance classes atone of the local technical colleges andthe team actively participates inbenchmarking, calls, and conferences

through various industry associations.At the end of the day, information

sharing is only ever a good idea, saysEilers: ‘Don’t be afraid to get a secondopinion. I’ve been fortunate to workwith some very knowledgeablecompliance professionals. The abilityto learn from each other and leverageprevious experiences to apply incurrent situations is critical.’

Runner-Up: Accenture

Accenture is the world’s largestconsulting firm. In 2015, it reported$32 billion in revenues and deployedover 370,000 employees, who serveclients in 120 countries and in everyindustry sector. With its vast globalfootprint and a client base thatincludes 94 of the Fortune Global 100and more than 80% of the FortuneGlobal 500, Accenture is exposed to awide range of risks in everyconceivable area of international tradecontrol.

Accenture’s Global TradeCompliance Team (‘GTCT’) is part ofthe company’s Legal Group under theEthics and Compliance function. JohnPisa-Relli, the company’s managingdirector of Global Trade Compliance,leads a team of seven trade complianceprofessionals, comprising four lawyerswho support specific geographic areas,a global director of asset classificationand trade logistics, and twoprogramme managers who overseekey compliance functions such asdenied party screening and whoprovide vital administrative support.Also working closely with the team aretrade compliance professionals fromAccenture’s key affiliates, Avanade, anAccenture/Microsoft joint venture,and Accenture Federal Services, whichoperates under strict U.S. nationalindustrial security requirements tohandle classified government work.

Nathan Eilers, Director, Global Trade Compliance,

Rockwell Automation

‘The GTC team helps the company achieve business

objectives in a manner that ensures compliance with

applicable regulatory requirements.’


Winner: TaiwanSemiconductorManufacturing Company, Ltd

TSMC (Taiwan SemiconductorManufacturing Company Ltd) is ourwinner in this category for 2016. Thecompany was nominated for theaward by a regular WorldECR

contributor, who wrote: [the team atTSMC] ‘have been the champions ofTaiwan industry’s export controlcompliance community going back adecade. Not only have they built uptheir own solid internal complianceprogramme and were among the firstcompanies in Taiwan to get theBureau of Foreign Trade’s (BOFT)

“ICP company recognition”, but theyhave since become a mentor tocompanies in their supply chain andthe Taiwan business community on

export controlcompliance, oftenassisting BOFT withtheir outreach efforts.’

The company is theworld’s largestdedicated independentsemiconductor foundry,it has a marketcapitalisation of £120billion, and doesbusiness all over theworld. An 80-stronglegal team, half of

whom are attorneys, plus about 15technical experts spread across threecontinents (Europe, China/Taiwan/Japan, and North America), seeks ‘to

Export Controls Compliance team of the year,

Rest of the World

According to Pisa-Relli, whatdifferentiates his team from others is‘its relentless drive to be commerciallyrelevant. The GTCT helps Accenture’sdeal teams manage trade compliancerisks from the earliest stages ofbusiness development throughdelivery and beyond, reusing andrefining practical methods to ensurethat the company can operate nimblyin an increasingly regulated worldmarketplace without compromising itsexacting ethical standards.’

One innovative way the GTCT helpsthe company manage risks is throughthe use of written trade complianceplans. Pisa-Relli explains that these‘range from standard guidance for low-risk, frequently recurring activities tocustomised plans for higher-risk work,such as support for multinationalclients in the defence and nuclearenergy industries. These plans provideclear and simple guidance, as well as ameans to monitor compliance for deals

that face elevated trade compliancerisks.’

According to Pisa-Relli, use of theseplans is driven in large part by anequally innovative approach to tradecompliance: ‘Accenture requires itsdeal teams to answer a few simplescreening questions as part of itsopportunity intake and managementprocess. Answers to these mandatoryquestions help the GTCT identify andsupport deals with elevated tradecompliance risks.

‘These trade compliance plans andopportunity management screeningquestions embody the GTCT’s guidingprinciples of simplicity, clarity, andrelevance... Most importantly, theseprinciples guide the team in its dailyinteractions with colleagues, businesspartners, regulators, and otherconstituencies.’

The team’s approach garnersexceptional praise from third parties:‘The Accenture team is top-notch –

attentive to cutting-edge issues, carefuland proactive in response to newdevelopments, and laser focused onpragmatic solutions for the business,’said Peter Flanagan, a partner at lawfirm Covington & Burling. The tradeteam at Crowell & Moring adds: ‘Onedefining characteristic of Accenture isits extremely challenging complianceobligations; no two projects are thesame. As a service provider to a broadrange of industries, Accenture isrequired to constantly adapt to theunique legal requirements applicableto each of its clients. Accenture’s tradecompliance team excels at this,seamlessly transitioning from sector tosector, issue to issue, and jurisdictionto jurisdiction. The team credibly andeffectively deploys resources to provideclear, concise, and business-focusedadvice time and time again.’

Pisa-Relli is singled out forcommendation: ‘Pisa-Relli's leadershipis key to the team's success. Arecognised expert with governmentand industry experience across a rangeof trade compliance issues, he hasconsistently demonstrated hisimpeccable judgement in bridging theoften difficult gaps between ambiguouslegal obligations imposed in dozens ofjurisdiction and the practical realitiesof advising a quintessentiallyglobalised business in the 21st century.He has assembled a stellar global team,and he knows how to let them shine.’

John Pisa-Relli, Managing Director of Global Trade

Compliance at Accenture

‘The GTCT helps Accenture’s deal teams manage trade

compliance risks from the earliest stages of business

development through delivery and beyond.’




create and manage the legalconditions in which TSMC maycomply with all applicable regulatoryrequirements including exportcontrols laws, supporting thecompany’s financial objectives withhigh integrity and sound riskmanagement.’

As a key player in the hi-techelectronics supply chain, TSMC doesbusiness worldwide withinjurisdictions like the U.S. and EU thathave stringent export controls lawsand regulations. ‘In order to maximiseuse of internal legal resources,TSMC’s senior management looked tothe Regulatory Compliance Division(a single department within theoverall Legal Department) to tacklethe difficult task of designing andimplementing an export controlmanagement system (‘EMS’) efficient

and flexible enough to supportTSMC’s enormous volume of shippingand pressing customer demands.’

To ensure compliance of applicableexport control laws, TSMC adopts a‘top-down’ strategy for policycommunication and a team approachto implementation. The teamresponsible for day-to-daymanagement of the export controlprogramme includes the attorneys inthe Regulatory ComplianceDepartment and EMS managers, who,with support from the RegulatoryCompliance Department and EMScoordinators, take resonsibility for:

l customer screening;l order screening;l ensuring that lists identifying

prohibited end-users are currentand available to relevant TSMCpersonnel;

l implementing equipment controls,including, but not limited, todisposition, transfer, upgrades,and enhancements of equipment;

l export control records retentionconsistent with companyprocedure;

l export control training;

l classification for items, technicaldata and software;

l ensuring that controlled items,technical data and software are notexported without relevant licences;

l ensuring that all regulatedequipment is used in compliancewith applicable export and re-export licence provisions andlicence conditions;

l ensuring the completion andmaintenance of necessary licensingdocuments regarding specifictransactions that are subject torelevant export control laws suchas the Taiwan Foreign Trade Act,the U.S. EAR and the ITAR;

l overseeing the process forapproving and supervising foreignvisitors and hires for the purposesof deemed export related issues;

l approving and routing all licensing

requests for processing by therelevant authorities;

l creating, maintaining and updatingthe various desginatedparty/country embargo lists.

As the world’s largestsemiconductor foundry, thecompany’s shipment volume is,naturally, massive. In addition toshipping product, the company mustmaintain customer technology,transfer equipment between facilities,and work closely with a globalsemiconductor supply ecosystem. Theteam ‘aims to ensure effectiveness andefficiency in export compliancethrough the development of automaticcontrol systems. To achieve the goal,we designed the control points atvarious key points in our businessstructure and process that monitorthe flow of all products, commodities,information, technologies, software,and people in TSMC and itssubsidiaries in an IT-drivenmechanism, including automaticcustomer, order and destinationcounties controls.’

The team utilises a global-coveragedatabase to screen employees and

customers against denied parties lists,require annual red flag reports oneach customer, and require customerexport classification information priorto initiating each new product.

‘To ensure our compliance withapplicable laws, we implemented a“No ECCN, No Production” on-lineplatform to obtain export informationsystematically from the customer. Wehave also enhanced our controls at theResearch and Development level toensure that technology developmentprojects are systematically managedthrough the same on-line system. Toensure the enforcement of this policy,Legal, as the project leader, took theinitiative to coordinate all relevantdepartments, ranging from HumanResources, Material Management &Risk Management, Operations,Research & Development, and Salesand Marketing, to improve variousexisting systems and design newsystems.’

As part of compliance with theBOFT Internal ComplianceProgramme, the company completesan annual Self-Check Report. Thecompany is committed to ongoingimprovement: ‘[W]e have beendeveloping more in-house expertiseboth in Taiwan and the U.S. forexport-related legal issues throughinternal coaching programmes,distribution of export-related legalupdates, and deeper communicationwith U.S. and Taiwan regulators andour outside counsel partners.’

In recognition of its EMSprogramme, TSMC was certified inSeptember 2012 by the BOFT as aqualified ICP exporter ‘whose exportapplications can be simplified to themaximum extent allowed by the laws;and we hosted a successful visit withthe Bureau to review our ICP activitiesin May 2016. Our export controlsystem has, in the past five years,passed a review by the Netherlandsexport authorities and our warehouseand logistics security control passed areview by U.S. Customs and BorderProtection.’

In a region of the world whereexport control compliance has nothistorically been high on the agendaof many corporations, TSMC has beena trail blazer in trade security and is tobe applauded for its achievements andcommitment to helping create safersupply chains and, ultimately, a saferworld.

‘ [A] mentor to companies intheir supply chain and theTaiwan business community on export control compliance.’


Winner: Baker & McKenzie

It was the law firm sanctions practiceinitiative of the year: Baker &McKenzie’s Iran Trade Roadshow, aseries of seminars across EMEA,rolled out in the weeks followingImplementation Day of the JCPOA,with a team of more than 20 expertspresenting in 20 offices in 14 countriesto 800+ representatives of 400companies, and making themselvesavailable to clients for one-to-onediscussion on the changing nature ofIran business and controls. An effortto be admired and applauded.Additionally, the firm should becongratulated on its excellentsanctions blog atsanctionsnews.bakermckenzie.com asfurther evidence of its desire to go theextra kilometer for its clients.

Inevitably, a lot of time – thoughnot all – was spent advising clients onIran sanctions. Instructions included:

l Representing a major internationalpharmaceutical company in tradesanctions investigations andproceedings before the competentSwiss authority. This was one of thefew Iran sanctions cases that theSwiss authority investigated.

l Advising an automotive companyon general and sectoral sanctionsimposed by the U.S., EU, Canada,Australia, Norway and Switzerlandon Russia, as well as the sanctionsimposed by the Russian authoritiesagainst foreign states.

l Providing a European flag carrierongoing trade compliance advice,notably with regard to EU and U.S.sanctions against Iran. Inparticular, guiding the client on itsre-engagement with Iran through areopening of its Tehran flight.

l Acting for a multinational with

operations in more than 100countries (including those subjectto sanctions such as Iran, Sudan,Russia, Myanmar and Belarus andthose with restrictive sanctionsregimes such as the U.S., Canadaand EU Member States).

l Assisting a luxury fashion companyon working out an internal policyand general guidelines onscreening of Russiancounterparties regarding theapplication of U.S. and EU-relatedsanctions.

Runner-Up: StephensonHarwood

The hub of Stephenson Harwood’ssanctions practice is in the firm’sLondon office, but it receives supportfrom team members in Dubai. Theteam has developed a leadingreputation for its work in financialsanctions, notably in acting forIranian companies challengingdesignations. In the past two years,the team has recorded five victoriesfor its clients in the General Court ofthe EU.

The firm acts for National IranianTanker Company (‘NITC’), one of thelargest tanker companies in the world,which was subjected to EU sanctionsin 2012. The firm represented NITC ina successful challenge to thosesanctions but in mid-February 2015,the Council of the EU re-imposedsanctions on NITC. Since then, the

firm has acted for NITC in itschallenge to those re-imposedsanctions. The firm notes: ‘The caseraises a very important issue whichwill be determined by the EU courtsfor the first time, namely that ofunfair and abusive relitigation of apoint or set of points that the Councillost in the first NITC case... Thedecision is eagerly anticipated bysanctions lawyers and could havesignificant implications on sanctionscases, and EU policy in relation tosanctions in future.’

Another high-profile matter hasseen the firm advising Bank Saderaton a claim against the Council of theEU, seeking compensation forfinancial and reputational damagecaused by the sanctions. According tothe firm, ‘The matter is of the utmostimportance to the Bank as thesanctions have prevented it fromcarrying out any new businessanywhere in the world. As far as weare aware, this is the biggest damagesclaim against the EU in connectionwith EU sanctions.’

Highly commended

Baker Botts: The sanctions team,led by Georg Berrisch and ChrisCaulfield, and supported by BrianByrne, counts globally recognisedRussian companies among its clients.The firm has been active in the pastyear advising these on the impact ofU.S. and EU sanctions on their tradeand financing needs. Otherinstructions came from a globaldrinks producer in relation to salesand payments (made in accordancewith EU law) which run to tens ofmillions of dollars to countriestargeted by EU sanctions, includingparticularly Iran. This has includedadvising in relation to the legality oftransactions and considering,

Sanctions Law Firm of the year, Europe


Sunny Mann and Jasper Helder

of Baker & McKenzie

Key contacts on the firm’s Iran Trade

Roadshow team



Winner: Latham & Watkins

Bill McGlone and Les Carnegie ‘knowtheir stuff!’ The two men lead theExport Controls, Economic Sanctions& Customs Practice at Latham &

Watkins in Washington, DC. Theteam handles significant and highly-sensitive matters for clients in theaerospace, energy, banking andfinancial, and high technologyindustries in connection with U.S.government investigations andenforcement actions arising undertrade and economic sanctions laws.

In one of the highest profile casesof the year, Latham representedSchlumberger, the world’s largestoilfield services company, in amultiple agency investigation ofalleged violations of U.S. sanctionsgoverning company operations inIran and Sudan. In April 2015, a non-U.S. subsidiary of the parent entitypled guilty to a one-count criminalinformation and paid US$233 millionin fines and forfeiture. The grand juryinvestigation was conducted by theD.C. United States Attorney’s Officeand the Counterespionage Section ofU.S. Department of Justice’s (‘DOJ’)National Security Division. The

global, six-year investigation by DOJinvolved novel and complex legal,factual and policy issues and coveredconduct throughout the world. Twoother U.S. agencies closed theirrelated investigations without takingany action against the company.

Meanwhile, Latham has helpedseveral humanitarian organisations,including CARE USA, theInternational Committee of the RedCross, and Mercy Corps, overcomecrucial barriers to providingemergency relief to Syria that are tiedto U.S. economic sanctions andstringent export control laws.

Over the Atlantic, attorneys in thefirm’s Brussels, London and Moscowoffices are also acting as counsel inhigh-profile litigation before the EU’sGeneral Court in Luxembourg,

challenging on behalf of VTB Bankaspects of the EU’s sanctions onRussia.

Runners-Up: Akin Gump andHogan Lovells

With more than 25 lawyers workingout of offices in the U.S., Europe, theMiddle East and Asia, Akin Gump

has one of the largest economicsanctions practices. In Washington,D.C., highly regarded practitionersinclude Shiva Aminian, Thomas J.McCarthy, Jonathan C. Poling,Edward L. Rubinoff and Wynn H.Segall.

The team has an impressivebreadth of experience representingcompanies on matters related to

Sanctions Law Firm of the year, U.S.A.

Bill McGlone and Les Carnegie of

Latham

The firm represented Schlumberger,

the world’s largest oilfield services

company, in a multiple agency

investigation of alleged violations of

U.S. sanctions.

amending and assisting in thenegotiating of bankingrepresentations/letters of comfort inrelation to the activities in question.

Clyde & Co has a leadingsanctions practice advising clients infive key sectors: insurance, aviation,marine, energy and internationaltrade. The highly regarded teamincludes partners John Whittaker,Chris Hill and Nigel Brook.

Over the last 12 months, the firmhas advised eight of the Top 10 UKinsurers on sanctions matters andassisted clients in the oil and gassector on preparing to enter theIranian market. Other instructionssaw it advise a leading tradingcompany in relation to a vesselcollision ultimately owned by aU.S./EU sanctioned entity.

Regular seminars and a sanctionsblog underline the firm’s commitment

to its clients in the area. The firmpartnered with the UK Department ofTrade & Industry in hosting a seminaron the opportunities for internationalbusinesses in Iran.

Hogan Lovells’ extensivenetwork of European sanctionslawyers in Brussels, Amsterdam,London, Moscow, Munich, Rome, andParis enable the firm to effectivelyaddress sanctions issues that span EUMember States and beyond. LourdesCatrain in Brussels is a leading exportcontrols/sanctions practitioner.

In the past year, the firm has actedfor an EU-listed mining and metalscompany which operates through itssubsidiaries throughout Central Asia.The company faces frequent supplychain sanctions risks and the firm hasbeen assisting it in distinguishingbetween legitimate financing optionsunder EU and U.S. sanctions, and

transactions that have no apparentcommercial rationale, requiring morecareful analysis.

The firm assisted a subsidiary of aglobal industrials conglomerate toinvestigate a potential historicsanctions violation involving theshipment of dual-use products toIran. It conducted a full review of therelevant transactions, includinginterviews, to determine otherpossible occurrences, and assistedwith a voluntary disclosure process infront of U.S. and German authorities,resulting in no penalties for the client.

Currently, the team is advising abanking software solutions specialistinterested in selling its financialsoftware into the Iranian market onthe evolving EU sanctionsenvironment and the regulationsgoverning export of encryptionsoftware.


sanctions programmes, includingthose over Cuba, Ukraine/Russia,Iran, Venezuela, Myanmar, Iraq andLibya. Recent examples include:

l Assisting a U.S.-based oil and gasservices company in obtainingOFAC licences in order to traveland provide services to oil and gascompanies operating in Russia andCuba;

l Advising a medical company basedin Sweden on international tradecompliance relating to the exportof equipment to Venezuela;

l Assisting a Cyprus-based mediacompany that was previouslysubject to majority ownership of aspecially designated national(‘SDN’) with the preparation of alicence application to OFAC for theunblocking of funds and otherproperty under the Ukraine/Russia-related sanctionsprogramme.

Hogan Lovells’ team boastssome of the most highly regardedsanctions lawyers in the countryworking on some of the most high-profile instructions. Team head, BethPeters led in helping Carnival CruiseLines obtain U.S. licences regardingvessel and service operations to Cubabefore the issuance of generallicences, as well as assisting STARRCompanies in obtaining U.S.

regulatory approval to engage intransactions with Cuba.

Legal analyses published bypartner Stephen Propst in 2011 and2015 regarding the legal authority ofthe President of the United States tomodify the sanctions against Cubawithout authorisation from Congress,is widely regarded as having played acontributing role in the ObamaAdministration’s decision to effectlandmark changes in the country’srelationship with Cuba.

Highly commended

Skadden, Arps, Slate, Meagher &

Flom, LLP represents a wide varietyof U.S. and international clients onregulatory, civil and criminal mattersinvolving U.S. and Europeaneconomic sanctions laws, includingthose administered by the Treasury’sOffice of Foreign Assets Control(‘OFAC’) and other federal and stateregulators, the EU, Her Majesty’sTreasury, and the French Ministry ofFinance, among others.

The firm ‘represented CréditAgricole CIB, and its parent, CréditAgricole SA, in connection with theresolution of a seven-yearinvestigation into Crédit AgricoleCIB’s compliance with U.S. economicsanctions laws between 2003 and2008.’ In addition, the firm is

representing several other Europeanfinancial institutions in pendingmulti-agency civil and criminalinvestigations.

Debevoise & Plimpton’s U.S.economic sanctions practice is hometo a dozen lawyers, including theformer U.S. Attorney General, aformer Under Secretary ofEnforcement at the U.S. TreasuryDepartment, the former head of thecriminal division at the U.S. JusticeDepartment, and a former seniorlawyer at the Federal Reserve Bank ofNew York. The team receives glowingendorsements: ‘DP has been a diligentpartner in providing comprehensiveanalysis and work product coupledwith aggressive time constraints. Inaddition, their customer service andrelationship management isexemplary in the area of Sanctionslaw.’ The past year has seen the teamadvise, among others,

l A U.S.-headquartered insurer onIran sanctions relaxations andapplicability of General License Hfor its non-U.S. subsidiaries;

l Russian clients on U.S. sanctions,including specific advice tied topotential acquisitions and onissues related to U.S. and E.U.persons serving on boards ofdirectors, and advice to U.S. clientson measures taken by Russia inresponse to U.S. and EU sanctions.


Winner: SECURUS StrategicTrade Solutions

‘The SECURUS team has provided us

with excellent advisement and

customer service on complex export

compliance issues... Their

responsiveness and attention to

detail is much appreciated.

‘We have had several significant

line/plant closures and other

facilities shut down. These were at

global non-U.S. sites and some of the

local teams did not have a lot of

experience with local export controls

at that time. Jay and his team were

instrumental in helping us sift

through thousands of pieces of

equipment, checking against both

local export regulations as well as

any other re-export regulations that

may apply, U.S. or otherwise, and

worked to drive many of the technical

related questions. This was over the

course of a year as we had multiple

lines and facilities shut down and the

assets moved. His team has also

provided assistance to us on

comparing and contrasting export

compliance regimes and structures

so we could develop processes to

classify and identify export issues for

Export Controls Controls Consultant of the Year

Jay Nash and Ryan Lynch Cathie

of SECURUS Strategic Trade

Solutions

Founded in 2010, with the mission of

providing highly personalised,

affordable, fast service to both private

and public partners, with a special

focus on global trade regulation and

compliance, particularly in major

emerging and developing markets.



local requirements. In fact, Jay is

currently assisting with another line

closure and helping to wrap that up.

His team has also assisted with

technology transfer questions, to

include encryption transfers outside

of the U.S.’

Export control manager, automobilemanufacturer

The four founding members ofSECURUS (Jay Nash, ManagingDirector of Strategy & Development;Ryan Lynch Cathie, ManagingDirector of Products & Innovation;Lara Howe Stenberg, ManagingDirector of Administration & Finance;Richard Glen Young, ManagingDirector of Operations & Analysis)met while serving as associates at auniversity research centre thatspecialised in foreign trade regulationresearch, training, and outreach. Theyformed SECURUS in 2010 with themission of providing highlypersonalised, affordable, fast serviceto both private and public partners,with a special focus on global traderegulation and compliance,particularly in major emerging anddeveloping markets.

In the past five years, SECURUShas expanded to include a vibrant andtalented team of staff consultants andglobal working partners, and itsclients have included some of theworld’s top automotive, engineering,and chemicals traders as well asgovernment trade regulatory andassistance agencies.

The company works with clientsfrom all industry sectors to help themdetermine whether strategic tradecontrols apply to their goods andtechnologies, and navigate therelevant licensing rules andprocedural requirements when theydo. SECURUS specialises in cross-and multi- jurisdictional exportcontrol classification, from chemicalsand industrial machinery toencryption, electronics, guidance andnavigation equipment in accordancewith non-U.S. export control systems.Other services include ICP audits,support on automation and training.The team, which also draws onindependent local expertise andwhich provides a number of servicesrelated to strategic trade controls forthe benefit of U.S. and foreigngovernments, has worked for clientsin more than 90 countries, from

Afghanistan to Yemen. Someexamples of recent instructionsillustrate the scope of services:

l Classifying industrial testequipment for a U.S.manufacturer’s R&D teams inaccordance with the Israeli andUAE export control systems, andhelping obtain the necessary exportlicences. SECURUS recognisedunique Israeli restrictions on thetransfer of low-level, commercialencryption and navigated UAEimport controls on certaintelecommunications equipment.

l Assisting one of the Big Threeautomotive companies withdetermining the U.S. and localexport control status of severalthousand items being transferredfrom India, Indonesia, Egypt,Kenya, and Vietnam. SECURUSdetermined the items subject toexport licensing requirements anddetermined the appropriate exportcontrol classification number(‘ECCN’) for those items in theirrespective jurisdictions.

l Preparing a database ofcomparative export controlclassifications for more than 60different items across 10 differentnon-U.S. jurisdictions for one ofthe world’s largest chemicalmanufacturers.

Runner-Up: Deloitte GlobalExport Control andSanctions

The well-known and highly regardedteam at Deloitte focuses on‘addressing the operational challengesfaced by companies whenimplementing controls to comply withexport regulations. We help clientsunderstand the rules and regulationsthat apply to their business’. Global

team leader, Stacey Wintersestablished the first big fourprofessional services fully dedicatedexport control practice in the UK in2002. Other prominent members ofthe team are: Pablo Lecour, SuzanneKao, Stacey Toder Feldman andEmily Cromwell.

The team is clearly doing a lot right– we received a good number ofglowing endorsements from clients,including the following from theglobal director of export controls in ahousehold name multinational: ‘Ihave worked with Stacey and her teamfor many years. What I find appealingwith the Deloitte team is that apartfrom being very professional andknowledgeable, they also have acapacity to support in many differentways. Not only regarding legal aspectsin many jurisdictions, but also how tobest set up procedures of a wellworking compliance programme.Their capabilities in the IT area arevery impressive. I also appreciate theintegrity and candidness of theirsupport. I know that they will tell mewhat I need to hear.’

The team reports that the past yearhas been busy. They were instructedto help a global technology clientaddress some UK export controlchallenges that had put at risk £350mof business. The company needed anew export control programme,particularly focused on encryptionsoftware – classification of thesoftware, licensing, and transfermanagement. With a globaldevelopment environment, it wasextremely challenging to identify howexport control processes could beembedded across the business,including dealing with whatapplications required classification,how the software was beingtransferred and how UK licensingconditions could be met, particularlythe need for end-user undertakings.

Stacey Winters leads Deloitte Global Export

Control and Sanctions

‘We like a challenge. We like export controls. In

fact we love this industry. We are passionate

about what we do and who we do it for. We are

committed to delivering exceptional service to our

clients day in day out and we will go the extra

mile for them. We take pride in the brands we

work with and we have a lot of fun along the way!’



The outcome of the engagement wasagreement from the UK’s ExportControl Organisation to pilot the firstelectronic undertaking concept forOpen Individual Export Licenceusers; a new classification and licens -ing process for the client and releaseof the holds on the £350m business.

While over 50% of clients are inthe Aerospace & Defence sector, theteam works with clients across theboard, including public sector,financial services, consumer products,food and drink, technology,telecommunications, media,chemicals, pharmaceuticals,healthcare, oil and gas, energy,industrial products, and automotive.

Highly commended

Full Circle Compliance: It’s takenjust a few short years for FCC to makeits mark on the export complianceworld. Well-known consultants at theEurope-U.S. consultancy include Jim‘Daily Bugle’ Bartlett, ex-PWC partnerMike Farrell, and Ghislaine Gillesen

(Gillessen was the first independentauditor to be contracted by the Dutchgovernment to perform a tradecompliance audit of the DutchMinistry of Defense).

FCC is an integrated ‘one-stop’export controls compliance servicecentre with hands-on experienceworking with industry members andgovernment authorities. The companyhas developed a trade compliancemanagement system, or ICPframework (including auditmethodology) that allows it tocategorise, benchmark, prioritise, andmanage risks, and so helporganisations avoid trade complianceviolations. Services include, but arenot limited to:

l Global compliance audits,including risk assessment and gapanalysis;

l Reviewing, designing, andassessing ICP effectiveness;

l Calculating the operational burdenand formulating budgetrequirements;

l Identifying and helping to

prioritise employee training needs.Last year, WorldECR reported that

FCC was behind the very welcomeintroduction of a part-time ExecutiveMasters in International TradeCompliance in partnership with theUniversity of Liverpool. Theprogramme is designed forprofessionals who

l want to progress the tradecompliance efforts at theirorganisation;

l need to raise the awareness levelsof international trade compliancewith their board and seniormanagement;

l want to instill a compliance cultureat their organisation and ensure itis viewed as a business enabler;

l want to balance the costs andbenefits of compliance at theirorganisation;

l need to quantify and qualify theirbudgetary requirements.

FCC reports that a year on, theprogramme is already very popular.

Amber Road provides a single platform that plans and executes all aspects of global trade. By enabling companies to take a holistic, integrated approach to global trade, Amber Road accelerates the movement of goods across international borders, improves customer service and reduces global supply chain costs.

Amber Road includes deep functional capabilities across all areas of global trade – trade compliance, supply chain visibility, restricted party screening and origin management. Underpinning all of these solutions is Global Knowledge®, the most comprehensive, intelligent repository of global trade content available anywhere.

A new horizon

for Global

Trade Management

For more information, please contact us at [email protected], or visit www.AmberRoad.com.

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