Grammas, George N.

George N. Grammas

Partner

George N. Grammas leads our International Trade Practice Group, which includes global import and export compliance. George spends 100% of his time representing clients in export controls, sanctions, anticorruption, the Committee on Foreign Investment in the United States (CFIUS) clearance and other US and global international trade regulatory and compliance matters. He has an established record of successfully representing clients in enforcement matters and offering creative and practical trade compliance advice and solutions for companies operating in a wide range of countries, including in Europe, the Americas and the Asia Pacific region.

Over the past 28 years of practice in export controls and sanctions, George has served as an adviser to industry associations and the US government, including as an industry adviser to the State Department’s Bureau of Politico-Military Affairs through the Defense Trade Advisory Group; co-chair of the Joint Defense Trade Committee of the Electronic Industries Alliance and the Aerospace Industries Association; chair of the export controls committee for CANEUS International, a micro/nano technology association; international trade counsel to the Electronic Industries Alliance; and legal adviser to the Society for International Affairs, the government/industry association on defense trade and export controls.

George is highly regarded as one of the leading practitioners on aerospace, military, security and space export controls under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). In addition, he has many years of experience in specialty chemicals and materials exports. With a background in computer programming, George began his career in electronics technologies and, through current day, he continues to focus on encryption, software, semiconductors, and electronic systems and subsystems exports. Further, over the past decade, George has spent considerable time in Europe; based in our London office, he has achieved an unparalleled understanding of the challenges, lessons-learned and best practices for non-US organizations seeking to comply with US export controls and sanctions regulations.

In today’s continually globalizing environment, companies must comply with the international trade requirements in the countries in which they operate. For numerous companies, George has navigated the labyrinth of varying regimes and requirements in export controls, sanctions, anticorruption and customs to achieve a seamless global compliance solution and to optimize trade flows and operations.

In addition, George has successfully handled hundreds of internal investigations and voluntary disclosures involving possible or suspected violations of export controls (ITAR, EAR), sanctions (OFAC, EU sanctions), anticorruption (FCPA, UK Bribery Act) and customs matters. His experience in handling enforcement actions informs the standards of compliance in global compliance programs that we help develop for clients.

Finally, George guides non-US companies through the regulatory barriers to enter or expand their operations in the US by clearing regulatory hurdles, including CFIUS, as well as notices and clearances from Departments of Defense and State. George was involved in some of the earliest CFIUS clearances in the 1990s under the Exon-Florio Amendment that established the current CFIUS process. His in-depth understanding of US national security industrial base and technology transfer policy guides companies in the decision-making process prior to filing and the optimal approach for clearing transactions.

George frequently speaks on the ITAR, EAR and other trade compliance matters in the US and Europe. He is also a co-author of the Squire Patton Boggs ITAR Practitioner’s Handbook, and a regular contributor to the Trade Practitioner Blog.

Explore

International Trade Compliance

  • Developing and deploying a trade compliance program across the US facilities and facilities in EU and Asia Pacific countries for a specialty chemical company including compliance policy, manual, procedures and awareness training.Ÿ
  • Conducting an international trade compliance risk assessment of a multinational defense industry company, followed by internal investigations in the areas of export controls, economic sanctions and FCPA compliance, and voluntary disclosures to regulators.
  • Serving as an export controls ombudsman for a multinational aerospace business including resolving day-to-day licensing and compliance matters, drafting compliance procedures, and drafting and implementing the training program.Ÿ
  • Establishing procedures and obtaining (deemed export) approvals for non-US citizen employees, professors and students working in the lab of a major educational institution.Ÿ
  • Establishing international trade compliance policies and procedures, providing compliance official and empowered official training and compliance awareness training in export controls, economic sanctions, customs and FCPA for numerous companies annually.

Export Controls

  • Assisting a US-based automatic test equipment company in negotiating and drafting contracts and in obtaining US State Department approvals for the export of defense articles and defense services in support of NATO, Middle East and Japanese aircraft maintenance programs and direct manning personnel for the F-15, AWACS and other military platforms.
  • Assisting a US-based information security company in determining US, French and Chinese export and import requirements and restrictions for dual-use encryption technology and obtaining mass market treatment for the products from the US Commerce Department.
  • Developing and implementing strategy for sales, manufacturing and distribution of defense articles and defense services through affiliated companies in the United States and EU under technical assistance agreements and distribution agreements approved by the US State Department.
  • Obtaining a commodity jurisdiction determination that a component used in spacecraft applications is under Commerce Department dual-use export licensing jurisdiction.
  • Assisting a commercial communications satellite company in obtaining authorization to engage in final assembly and testing operations in Russia of communication satellites as well as authorization to launch from Russia.
  • Conducting internal investigations and voluntary disclosures of export compliance for numerous companies every year.

Economic Sanctions

  • Determining the application of OFAC regulations to a non-US automaker’s operations in sanctioned countries.Ÿ
  • Submitting a voluntary disclosure to OFAC concerning repair of aircraft equipment for an SDN.Ÿ
  • Evaluating services that could be performed on or for oil platforms and ships operating in Iranian territorial waters.
  • Evaluating the application of US economic sanctions to dry leases and wet leases of aircraft on temporary sojourn to sanctioned countries for a non-US carrier and submitting voluntary disclosure to OFAC.
  • Obtaining licenses for export of medical devices to US-sanctioned countries.
  • Investigating possible violations of US economic sanctions and submitting voluntary disclosures to OFAC.

FCPA/Anticorruption

  • Serving as independent FCPA counsel for joint venture owned 50/50 by a non-US government instrumentality and US company.
  • Investigating possible FCPA violations in Russia and implementing compliance measures for a global telecom equipment manufacturer.
  • Evaluating the application of FCPA to oil industry joint venture activities in Latin America.
  • Drafting and implementing FCPA, antimoney-laundering, antiboycott and export controls compliance provisions in a Middle East agency agreement for a large defense contractor.
  • Investigating red flags that arose under FCPA compliance program related to overseas sales representatives.
  • Providing anticorruption compliance training for an aerospace company in the US, UK and China.

Customs

  • Conducting an internal/simulated customs focused assessment for a multinational importer and making recommendations to strengthen compliance measures and pass a future customs focused assessment.
  • Establishing proper customs valuation and classification for large capital equipment imports through a series of ruling requests and protests.
  • Developing strategy for minimizing tariff obligations and establishing proper valuation, classification, origin and marking requirements for global companies.
  • Defending a US-based company’s foreign trade subzone status against challenges raised by a US supplier.
  • Representing parties in antidumping proceedings including electrolytic manganese dioxide from China, polyvinyl alcohol from China, aspirin from Turkey, calendar slides from Japan and flexible magnets from China and Taiwan.
  • Persuading Customs to change its position concerning the classifications of merchandise through an internal advice request, protesting entries based on disputed classification and submitting a prior disclosure as a protective measure.

Foreign Investment/Access to US Defense and Critical Infrastructure Industries

  • Acting as special counsel to a large Germany-based defense contractor on CFIUS and Defense Security Service approvals for acquisition of a cleared US-based contractor and participation in US government programs.
  • Acting as special counsel to an Italy-based high technology company in acquisitions in the United States, clearing CFIUS review and bringing acquired companies into compliance with US export control requirements.
  • Obtaining access to US defense industry through government approval granting the non-US company access to government and contractor RFPs (including controlled technical data) for all current and future programs related to the company’s product line during the life of the approval.
  • Clearing an acquisition of a US-based telecommunications company by a China-based government-owned enterprise.
  • Clearing CFIUS reviews involving many other acquisitions in the defense, high technology, telecommunications, chemical, energy and transportation industries.


Education

  • William Mitchell College of Law, J.D., 1988
  • Lawrence University, B.A., cum laude, 1984

Admissions

  • District of Columbia, 1990

Courts

  • U.S. Ct. of App., Federal Circuit, 1991
  • U.S. Ct. of International Trade
  • U.S. Court of International Trade, 1990

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  • US Export Controls Workshops – "The ITAR 'Virus' EARvolves!" Stratford-upon-Avon, UK, July 18-20, 2016.
  • “Breaking Down the New US Export Controls Framework and Tackling the Most Challenging Issues,” marcus evans® 6th Advanced ITAR and EAR Compliance Conference, Arlington, VA, February 23-25, 2016.
  • “U.S. Export Controls – Intermediate Workshop,” UK Department for International Trade, Export Control Organisation, September 22, 2015.
  • Comparative Overview of EU and US Economic Sanctions Regimes,” Squire Patton Boggs Seminar “Financial Sanctions in Practice:  What You Need to Know to Comply,” London, UK, June 15, 2015.
  • Regulatory Issues:  US & UK Export Controls, Committee for Foreign Investment in the US, US Acquisition Regulations and US Security Clearances,” Squire Patton Boggs Seminar “Opportunities for UK Companies in the US Defence and Security Markets,” Birmingham, UK, June 12, 2015.
  • US Export Controls Workshop – "The ITAR 'Virus' EARvolves!" Stratford-upon-Avon, UK, June 9-11, 2015.
  • Some Legal Advice Can’t Hurt:  An Intro to International Crypto-law,” 2015 mGuard International User Conference, Houston, TX, June 3-4, 2015.
  • What to Expect When DDTC Requests Outside Monitoring,” SIA 2015 Spring International Trade Export Licensing & Compliance Conference, Los Angeles, CA, May 3-6, 2015.
  • Analyzing the Current State of Export Controls Reform and Creating a Framework for Your Compliance Toolbox,” Marcus Evans 5th Advanced ITAR Compliance and Export Controls Conference, Arlington, VA, February 18-20, 2015.
  • “Managing ITAR and EAR Controlled Technical Data and the Impacts on Employment, Facility Visit and Dealings with US and non-US Contractors,” Marcus Evans 4th Advanced ITAR Compliance Conference, Arlington, VA, February 11-13, 2014.
  • US Export Controls Workshop – "The ITAR 'Virus' EARvolves!" Bristol, UK, November 3-5, 2014.
  • “Main Issues and Trends in Mergers & Acquisitions: Brazilian and International Perspectives,” Joint Seminar – Squire Patton Boggs and Castro, Barros, Sobral, Gomes Advogados, Rio de Janeiro and São Paulo, Brazil, August 12 & 14, 2014.
  • US Export Controls Workshop – "The ITAR 'Virus' EARvolves!" Stratford-upon-Avon, UK, July 8-10, 2014.
  • ITAR Three-Day Workshop, Chester, UK, October 8-10, 2013.
  • US Export Controls Workshop – "The ITAR 'Virus' EARvolves!" Stratford-on-Avon, UK, June 11-13, 2013.
  • “Managing Complex ITAR Licensing and Compliance Challenges Affecting Suppliers to Non-U.S. Customers: Practical Impact of US-UK and US-Australia Treaties and Other Key Considerations,” American Conference Institute’s National Forum on ITAR Compliance, Washington, DC, July 24-25, 2012.
  • “ITAR Workshop – How to Cure the Virus,” UK A|D|S/EGAD 2012, Leatherhead, Surrey, UK, July 3-5, 2012.
  • “Workshop – A Complete Guide to Preventing Defense Services Export Violations: Fostering Worldwide Compliance across Your Engineering, IT, Procurement and Sales Teams, and Avoiding ITAR Taint of Commercial Services,” American Conference Institute’s 6th National Forum on “International Technology Transfers & Deemed Export Compliance,” Washington, D.C., September 28, 2011.Ÿ
  • “ITAR Workshop – How to Cure the Virus,” UK A|D|S/EGAD 2011,” Stratford-Upon-Avon, Warwickshire, UK, June 14-16, 2011.
  • “Impact of ITAR on Aerospace R&D:  Understanding the Problems and Possible Solutions,” ISC Intelligence, Brussels, Belgium, June 24, 2011.
  • C5 Export Controls Conference, Paris, France, “Voluntary and Directed Disclosures,” December 2010.
  • ITAR Boot Camp, American Conference Institute, “Avoiding Unauthorized Exports of Technical Data and Defense Services,” October 2010.
  • ITAR Boot Camp, American Conference Institute, “License Exemptions under the ITAR,” October 2010.
  • “ITAR Workshop – How to Cure the Virus,” UK A|D|S/EGAD 2010, Stratford-Upon-Avon, Warwickshire, UK, July 12-14, 2010.
  • Defense Export Controls Conference, American Institute of Engineers, “Avoiding Unauthorized Exports of Technical Data and Defense Services,” November 2009.Ÿ
  • Coping With Export Controls in Mixed Commercial and Military Business: “Turning the ITAR on Its EAR,” Fairfax County Chamber of Commerce, International Business Exchange Council, October 2009.
  • Complying with Export Controls on International Tech Transfer, American Conference Institute, “Export Compliance and Licensing: Stored and Transmitted Data,” September 2009.
  • “ITAR Workshop – How to Cure the Virus,” UK Defense Manufacturers Association/EGAD 2009, Stratford-Upon-Avon, Warwickshire, UK, June 8-10, 2009.
  • “ITAR and Government Policies and Approvals for International Collaboration,” CANEUS 2009, NASA Ames Research Center, Moffett Field, California, March 1‑6, 2009.
  • “ITAR Controls on Technology Transfers and Outsourcing,” GOCA/DOIA 2008, Coeur d’Alene, Idaho, Oct. 13-16, 2008.
  • “ITAR Workshop – How to Cure the Virus,” UK DMA/EGAD 2008, Bracknell, Berkshire, UK (July 7-10, 2008) and Stratford Upon Avon, Warwickshire, UK, Nov. 19-20, 2008.
  • “ITAR Issues,” NDIA Manufacturing Division Conference, Arlington, Virginia, Nov. 14, 2007.
  • “Dual/Third Country Nationals,” sponsored by the Society for International Affairs, Washington DC, June 11, 2007.
  • “ITAR Workshops – How to Cure the Virus,” UK Defense Manufacturers Association/EGAD 2007, Warwickshire, UK, April 3-4, 2007.
  • “Gateway to India 2006: Opening the Golden Door: Paving the Way for Business Success,” International Business Exchange Council (IBEC), International Trade Association of Northern Virginia (ITANV), Confederation of Indian Industry (CII), Department of Commerce and TiE-DC, McLean, Virginia., Dec. 4, 2006.
  • “Strategies for Complying with the ITAR in the Context of Collaboration in Aerospace Applications,” CANEUS 2006: Conference on Micro and Nano Technologies for Aerospace Applications, Toulouse, France, Aug. 27-Sept. 1, 2006.
  • “Export Compliance in the Context of International Marketing and Business Development,” Law Seminars International: A Comprehensive Tour of Key Legal Areas for Corporate Counsel, McLean, Virginia, June 19, 2006.
  • “Employing Foreign Nationals: Laws, Threats, Practices,” INTELCON 2nd Annual National Intelligence Conference and Exposition, Bethesda, Maryland, May 8, 2006.
  • “Challenges and Opportunities When the Best Solutions Utilize Non-US Products,” International Business Exchange Council (IBEC), McLean, Virginia, Jan. 24, 2006.
  • Conference director and speaker at multiple conferences for the Society for International Affairs.