George N. Grammas

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.
• 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.
• Establishing procedures and obtaining (deemed export) approvals for non-US citizen employees, professors and students working in the lab of a major educational institution.
• 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.
• Submitting a voluntary disclosure to OFAC concerning repair of aircraft equipment for an SDN.
• 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 and CFIUS

• 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.