Alan represents clients in international trade and national security matters, government enforcement and investigations, and trade remedy disputes.
International Trade Strategies
Alan represents clients in all areas of international trade, including:
- Export Controls (ITAR/EAR and E.U. Dual-Use Controls)
- Economic/Trade Sanctions Programs (OFAC)
- Customs/Import Controls and CBP Seizure/Forfeiture Actions
- Trade Remedy Disputes (AD/CVD and §232 and §301 Tariff Strategies)
- Global Anti-Corruption Laws (FCPA and UKBA)
- Foreign Direct Investment/National Security Reviews (CFIUS)
- Foreign Agents Registration Act (FARA) Requirements
- National Industrial Security (NISPOM) Standards
- Anti-Money Laundering (AML) Compliance
- Arms Industry Munitions Trade Compliance (ATF)
- Anti-Boycott Restrictions (Commerce and Treasury)
- Aerospace and Autonomous Systems Development Strategies
- Defense and Global Security Assistance Project Strategies
- Trade Agreements and Foreign Market Access Strategies
Alan helps clients "get to yes" and capitalize international market opportunities by guiding them through the necessary international trade requirements in a manner consistent with their risk tolerance and business objectives. This often involves the establishment of tailored international trade compliance and risk mitigation strategies; advice on international product development, classification, and licensing issues; guidance on the simultaneous navigation of multiple regulatory regimes; and identification of new market opportunities in both commercial and defense sectors created by U.S. export control reforms or free trade agreements.
Government Investigations and Regulatory Enforcement
Alan assists clients with internal and government investigations of trade-related matters, including potential violations of export controls, embargoes/trade sanctions programs, customs regulations, and global anti-corruption laws, as well as unsanctioned foreign boycott requests and CFIUS/national security reviews.
He has successfully represented dozens of clients through voluntary disclosure and penalty mitigation processes, and handles enforcement disputes before the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC), the Defense Technology Security Administration (DTSA), U.S. Customs and Border Protection (CBP), and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). He has also represented clients during external investigations by the U.S. Securities and Exchange Commission. Alan represents former military personnel before the U.S. Department of Defense and other government agencies in connection with their obligations to the U.S. government regarding the non-disclosure of classified information.
Global Trade Disputes
Alan represents domestic and non-U.S. clients in antidumping and countervailing duty litigation, including investigations, annual reviews, and scope rulings. He has litigated asset forfeiture cases in the U.S. District Court for the Southern District of New York and before U.S. Customs and Border Protection. He has also handled disputes for clients involving intergovernmental organizations, including contractual disputes with the North Atlantic Treaty Organization (NATO), as well as cross-border commercial disputes. Alan has represented clients before Congress and other federal agencies on matters involving international relations, including initiatives focused on advancing political, economic, and human rights reforms in Central Asia.