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- Practices and Industries
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- International Trade
As companies have developed their global footprint, the relevance of international trade and investment law has expanded.
Described as a “preeminent trade group with market-leading strength in a broad range of areas of international trade,” by Chambers and Partners, Covington offers full-service international trade services to the world’s leading companies.
Our lawyers and policy experts have held senior positions in the Office of the U.S. Trade Representative, the International Trade Commission, the U.S. Departments of State, Treasury, and Commerce.
We have a strong trade practice in Europe, where members of our team have held senior positions in the European Commission’s Directorate General for Trade, in the European Parliament’s Trade Committee, in the Council, and as UK Trade Minister.
Trade Controls
Described as “the leading firm for export control issues,” Covington advises on U.S. and EU trade controls, including export controls, economic sanctions, and anti-boycott laws and regulations.
With trade control lawyers based in Asia, Europe, and North America, we help clients navigate compliance with trade control laws and regulations around the world. Our work includes:
- advising on compliance with export controls, including export jurisdiction and classification;
- developing and implementing export controls and sanctions compliance programs;
- counseling on the frequent changes in sanctions programs and export control regulations;
- providing counsel and assistance on interpretive matters, and obtaining licenses and other authorizations;
- advocating changes in regulatory programs and legislation;
- conducting risk assessments, compliance reviews, and internal investigations;
- preparing disclosures to U.S. government agencies, defending clients in administrative and criminal enforcement cases, and negotiating settlements of trade controls matters; and
- conducting and responding to due diligence and otherwise representing clients on the trade controls dimensions of M&A activities.
Trade Law, Policy, and Disputes
Through various international agreements, countries have made commitments to open their markets to foreign suppliers. We assist clients in pursuing these commitments in negotiations. We also assist clients in enforcing commitments that have been made. Our clients benefit from our extensive senior level government experience in trade policy and market access issues, including as Deputy U.S. Trade Representative, Deputy Secretary of the Treasury Department, Under Secretary of State for Economic Affairs, Assistant Secretary of Commerce, and Senate Finance Committee staff—and, in Brussels, as Deputy Director-General for Trade in the European Commission, a senior member of the European Parliament’s International Trade committee, President of the Council, and UK Trade Minister.
We help clients respond to violations of trade commitments through both formal and informal mechanisms, and we regularly assist private companies, trade associations, and governments in disputes arising under the WTO Agreements, NAFTA, EU Free Trade Agreements, and other international instruments.
We have also assisted numerous private companies and a number of governmental entities in successfully navigating U.S. trade remedy laws, including:
- antidumping and countervailing duty (CVD) laws, including appeals of these cases to the U.S. Court of International Trade (CIT) and the Court of Appeals for the Federal Circuit;
- proceedings under Section 201 (“escape clause”), Section 301 (authorizing retaliation against foreign countries that restrict access to their markets), Section 232 (effect of imports on national security),and the Generalized System of Preferences (GSP); and
- dispute-settlement proceedings arising under NAFTA and the WTO Dispute Settlement Understanding.
Our practice includes the former Chair of the U.S. International Trade Commission. In Brussels, we have assisted clients in litigating EU anti-dumping matters before the Court of Justice of the European Union.
Our team has also advised clients on the negotiation of every important U.S. free trade agreement of the past decade, helping our clients achieve objectives in such diverse areas as technical standards, intellectual property, e-commerce, government procurement, and competition policy. Our team has extensive experience with EU free trade agreements, and is in a position to help clients engage in the negotiation and implementation of such instruments.
Customs
Covington advises on a range of U.S. customs compliance matters, including:
- the proper classification and valuation of imported merchandise;
- country-of-origin marking and labeling requirements;
- customs bond obligations;
- harbor maintenance and merchandise processing fees;
- American Goods Returned;
- the establishment and operation of Foreign Trade Zones (FTZs);
- the Generalized System of Preferences (GSP); and
- NAFTA and other trade preference programs.
We also help clients develop and implement customs compliance programs and represent clients in audits conducted by U.S. Customs and Border Protection (CBP).
Iran sanctions advice for a financial services provider
Represented a multinational financial services provider in strategic matters relating to potential Court of Justice of the European Union (CJEU) litigation pursuant to the EU sanctions against Iran.
Iran Sanctions Investigation for Pharmaceutical Company
Conducted an Iran sanctions investigation for a major pharmaceutical company.
Iran and Sudan Sanctions Advice
Secured export licenses enabling leading pharmaceutical companies to sell millions of dollars’ worth of medical products to Iran and Sudan, and permitting consumer products companies to export agricultural commodities to those countries.
Iran retaliatory sanctions
Have helped companies understand U.S. retaliatory sanctions directed at Iran (through the Iran Sanctions Act as recently amended by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, or CISADA) and counterpart EU measures.
Libya and Syria sanctions advice
Advised companies regarding U.S. and EU sanctions on the Qaddafi regime in Libya and the Assad regime in Syria, including obtaining licenses to permit certain ongoing business activities in Libya.
Complex Procurement
A government entity needed to purchase a large number of military vehicles. The procurement required contractors and technology from several jurisdictions and a long-term supply arrangement. From international trade controls and U.S. and EU military sales advice to commercial terms, Covington provided strategic direction as we simultaneously ensured that the documents met local and international requirements.
Economic Cities Authority of the Kingdom of Saudi Arabia project
Representing the Economic Cities Authority of the Kingdom of Saudi Arabia in the development of legal and regulatory infrastructure for the Kingdom’s Economic Cities project.
Oil and gas company Iran sanctions
Extensive advice to U.S. and non-U.S. oil and gas companies on the scope and application of sanctions and retaliatory measures targeting Iran, including advice on pending U.S. enforcement matters.
Post-acquisition Compliance Review for Pharmaceutical Company
Conducted a post-acquisition trade compliance review for a global pharmaceutical company that included a voluntary disclosure to the U.S. Commerce Department. We also provided related Iran sanctions advice.
U.S. Sanctions Application Advice
Advised major international oil and gas companies concerning the application of U.S. sanctions against Iran, Syria, and other U.S.-sanctioned countries to their businesses.
March 2021
As the legal, regulatory, and commercial implications of coronavirus COVID-19 continue to evolve, our lawyers and advisors are helping clients navigate the complex considerations that companies around the world are facing and develop plans and strategies in response. Reach out to our COVID-19 task force at COVID19@cov.com. Below is a compendium of resources ...
October 14, 2020, Covington Alert
On October 8, 2020, the United States Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the imposition of comprehensive sanctions against 18 major Iranian banks. As part of the same action, the Treasury Department identified the “financial sector” of the Iranian economy as subject to sanctions under Executive Order No. 13902 (the ...
January 15, 2020, Covington Alert
On January 10, 2020, President Trump issued a new Executive Order (“January 10 Executive Order”) that provides authority for the imposition of sanctions with respect to certain additional sectors of Iran’s economy, including Iran’s construction, mining, manufacturing, and textiles sectors. The January 10 Executive Order introduces both property-blocking ...
April 25, 2019, Covington Alert
The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.
November 6, 2018, Covington Alert
The Trump Administration yesterday completed the reimposition of sanctions against Iran that previously were suspended as part of the 2015 multilateral nuclear agreement, known as the Joint Comprehensive Plan of Action (“JCPOA”).
August 8, 2018, Covington Alert
On August 6, 2018, President Trump issued Executive Order 13846 (the “Executive Order”) that re-imposes -- and to a limited extent broadens the scope of -- certain U.S. secondary sanctions targeting Iran that had been suspended in January 2016 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran.
July 2, 2018, Covington Alert
In furtherance of President Trump’s May 8, 2018 announcement that the United States is withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) (discussed in our recent alert), on June 27 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several changes to the U.S. sanctions against Iran.
June 15, 2018, Covington Alert
As described in our May 9, 2018, alert, the United States determined on May 8, 2018, to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK, and China.
May 15, 2018, Covington Alert
On May 8, 2018, the United States announced the decision to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK and China.
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
November 8, 2017, Covington Alert
During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and signed by ...
October 17, 2017, Covington Alert
On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not ...
July 28, 2017, Covington Alert
Congress has passed and sent to President Trump, for his signature or veto, a bill that would impose significant new sanctions against Russia, Iran, and North Korea. The legislation—the Countering America’s Adversaries Through Sanctions Act—enjoys broad bipartisan support, having passed the U.S. House of Representatives on July 25 by a vote of 419-3, and the ...
October 17, 2016, Covington Alert
Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. ...
May 4, 2016, The Wall Street Journal
David Addis is quoted by The Wall Street Journal in an article discussing technology exports to Iran, and how the Iran nuclear deal may pave the way for those exports. According to Addis, “Companies that were allowed to do trade in Iran found that even though they were able to sell devices, they had difficulty finding a financial actor” to facilitate the action. ...
- Latinvex Top Law Firms: Top Trade Firms (2018)
- China Law & Practice, International "Firm of the Year for Trade" (2017)
- Chambers USA - Award for Excellence in International Trade (2016)
- Law360, International Trade Group of the Year (2015, 2017-2018)
- Chambers Global, International Trade/WTO (2018-2020)
- Shara Aranoff was named an a Law360 MVP in the International Trade category (2018).
- David Fagan was named an a Law360 MVP in the International Trade category (2014, 2018).
- Mark Plotkin was named an a Law360 MVP in the International Trade category (2015, 2017, 2019).
- The International Trade practice was ranked Band 1 by Chambers USA (2016-2018).
- The International Trade practice was ranked as a Top Tier practice by Legal 500 US (2015-2017).
- World ECR - ‘Highly Commended’ for Export Controls Law Firm of the Year (Europe) (2015)
Global Supply Chain Toolkit
We help clients navigate the legal, reputational, and regulatory risks that can arise across their global supply chains.
Doing Business in China?
Covington helps clients validate or recalibrate their existing strategies for doing business in and with China.
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