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REPRESENTATIVE EXPERIENCE

Jeffrey Orenstein

Served as trusted advisor for multi-national corporations regarding U.S. sanctions, Export Administration Regulations (EAR), and International Traffic in Arms Regulations (ITAR), including advising on compliance, defending enforcement actions, preparing voluntary disclosures, obtaining licenses and commodity jurisdiction rulings, developing policies and procedures, and training personnel.
Obtained a portfolio of commercially valuable export licenses from the Bureau of Industry and Security (BIS), enabling U.S. technology and commodity companies to reach new markets and engage in strategic partnerships with counterparties in China, South America, and the Middle East.
Successfully petitioned the Office of Foreign Assets Control (OFAC) to remove numerous foreign companies and vessels from the Specially Designated Nationals and Blocked Person List, obtaining the fastest delistings on record, according to OFAC.
Provided transactional counsel on U.S. export controls, sanctions, customs, anti-corruption, and anti-boycott laws for a broad variety of commercial transactions, performing due diligence and drafting contractual terms that mitigate regulatory risks and clearly assign liabilities.
Advised numerous U.S. technology companies and foreign investors on Committee on Foreign Investment in the United States (CFIUS) regulations, including assessment of CFIUS risks, preparation of mandatory and voluntary notices, drafting of contract representations, and implementation of mitigation measures.
Designed comprehensive international trade compliance policies, procedures, and training programs for multinational corporations operating in numerous jurisdictions with differing regulatory regimes for export controls, sanctions, customs, and other trade laws.
Obtained valuable product exclusions from Section 232 and Section 301 tariffs on behalf of numerous U.S. manufacturers importing steel, aluminum, and Chinese-origin goods into the United States.
Represented U.S. manufacturer before Customs and Border Protection (CBP) in disclosure of fraudulent invoicing scheme, obtaining a favorable civil settlement with no CBP investigation or criminal referral.
Provided foreign embassy of major U.S. trading partner with weekly guidance on U.S. trade and industry developments, including advice on trade negotiations, import tariffs, export controls, sanctions, trade remedies, and regulation of foreign investment.
Represented pharmaceutical manufacturer before OFAC in voluntary disclosure of multiple violations of Iran sanctions, obtaining a final resolution with no civil penalty or enforcement action.
Represented dozens of U.S. importers in legal challenge of Section 301 tariffs before the Court of International Trade (CIT), preserving the right to seek multi-million dollar duty refunds.
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