George Grammas is a partner in the global law practice of Squire Patton Boggs, where he chairs the firm’s International Trade Practice, across our global network in over 40 offices on four continents.
George spends 100% of his time representing clients in export controls, sanctions, Committee on Foreign Investment in the United States (CFIUS) clearance and other US and global international trade regulatory, compliance, policy and national security matters.
Foreign Direct Investment (FDI) and CFIUS
George is among the most experienced practitioners before CFIUS, having practiced before CFIUS since 1990, the inception of notice filings of transactions before CFIUS, and representing investors, buyers and sellers in hundreds of transactions before CFIUS and assessing possible national security concerns. He is engaged frequently as special counsel by transaction parties or deal counsel on transactions to manage the CFIUS, export controls and security clearance notices and policy considerations to a timely conclusion with predictable results, minimizing deal risk. In addition to the notice process, George leads the firm (i) to provide CFIUS and related risk assessments, drawing on the firm’s depth of experience and resources on policy matters, and (ii) to provide global FDI assessments for multijurisdictional businesses, assessing the filing requirements in all relevant countries, utilizing our global platform.
George is equally expert in export controls, distinguishing him among CFIUS practitioners. Since the passage of the Foreign Investment Risk Review Modernization Act (FIRRMA), an in-depth export controls assessment of the target US business is necessary in assessing whether filing with CFIUS is mandatory for a given investment, acquisition or other transaction.
Export Controls and Sanctions
George has experience in all export controls matters and an understanding of all controlled technologies regulated under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), including semiconductors, aerospace, military, security, dual-use and space export controls, as well as a comprehensive understanding of the trade restrictions imposed by the Office of Foreign Assets Control (OFAC). He has many years of experience in specialty chemicals and materials exports and manufacturing equipment exports. With a background in mathematics and computer programming, he began his career in electronics technologies and, through the current day, continues to focus on encryption, software, semiconductors, communications and electronic systems and subsystems exports.
Further, George has spent considerable time in Europe and frequently visits China and Japan, where he achieved an unparalleled understanding of the challenges, lessons-learned and best practices for non-US organizations seeking to comply with the ITAR, EAR and OFAC regulations, including application of the de minimis, foreign direct product and 50% rules and other aspects of the extraterritorial application of US export controls and sanctions to non-US organizations.
Since 2007, George has co-hosted the preeminent US export controls training for non-US companies with the UK ADS trade association, including representatives from State, Commerce and Defense, frequently delivered the advanced US export controls workshops at the UK government’s annual symposium and represents the British Defense Staff at their US embassy on US export controls.
In addition, over the past three-plus decades of practice, George served on government and industry export controls committees, including as industry adviser to the US State Department through the Defense Trade Advisory Group; co-chair of the Joint Defense Trade Committee of the Electronic Industries Alliance (EIA) and the Aerospace Industries Association; chair of the export controls committee for CANEUS International; international trade counsel to the EIA; and legal adviser to the Society for International Affairs.
George is a co-author of the firm’s ITAR Practitioner’s Handbook and handbooks on navigating the CFIUS process and economic sanctions. He leads the content development for The Trade Practitioner blog. George is also a sought-after speaker at briefings and events on export controls and CFIUS and at company legal retreats.
International Trade Compliance
Foreign Investment/Access to US Defense and Critical Infrastructure Industries and CFIUS