Jeffrey Orenstein

Successfully petitioned 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.

Successfully obtained an OFAC license for a major electronics company that discovered Cuban-origin materials in its supply chain. The license unblocked the affected products and authorized the sale of affected products in the company’s inventory, preventing an international supply chain disruption.

Negotiated a settlement with OFAC involving over 200 violations for processing gift cards redeemed in embargoed countries. OFAC’s proposed penalty of US$6.8 million was negotiated down to US$200,000.

Successfully obtained OFAC licenses for vessel owners after the vessel’s cargo became blocked property. The licenses authorized all transactions necessary for the safety and maintenance of the vessel, and authorized the sale and discharge of the blocked cargo.

Provided transactional counsel on US export controls, sanctions, customs, anticorruption, and antiboycott laws for a broad variety of commercial transactions, performing due diligence and drafting contractual terms that mitigate regulatory risks and clearly assign liabilities.

Served as trusted adviser for multinational corporations regarding US sanctions, EAR and 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 BIS, enabling US technology and commodity companies to reach new markets and engage in strategic partnerships with counterparties in China, South America and the Middle East.

Advised numerous US technology companies and foreign investors on 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 US manufacturers importing steel, aluminum and Chinese-origin goods into the US.

Represented a US manufacturer before CBP in disclosure of a fraudulent invoicing scheme, obtaining a favorable civil settlement with no CBP investigation or criminal referral.

Provided the foreign embassy of a major US trading partner with weekly guidance on US trade and industry developments, including advice on trade negotiations, import tariffs, export controls, sanctions, trade remedies and regulation of foreign investment.

Represented a 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 US importers in legal challenge of Section 301 tariffs before the Court of International Trade (CIT), preserving the right to seek multimillion-dollar duty refunds.