John regularly counsels clients on the handling and coordination of multijurisdictional investigations involving alleged violations of international sanctions, export controls and customs regulations. He works with clients to assess their compliance risk profile and develop and implement fit for purpose policies and procedures for the identification and management of risk associated with cross-border activity, including: trade financing, import and export activity, investment transactions and enhanced counter-party screening and due diligence.

John regularly provides support to clients to assess compliance key considerations for specific transactions on issues such as:

  • Export control and customs related product classifications
  • The impact of restrictions on key equipment
  • Prohibitions on ancillary services such as technical assistance, transport and financing
  • Tariff classification and customs valuations
  • Preparation, submission and handling of authorisation requests
  • Voluntary disclosures to relevant competent authorities
  • Internal and external compliance reviews and audits
  • Remedial measures and mitigating circumstances
  • Free trade agreements and preference schemes

Key Experience

  • Advising a major private equity company on risk profiling and the development and implementation of associated policies and procedures to identify and manage trade compliance risk for its international group entities
  • Advising a number of international financial institutions, manufacturers, trading houses and consultancy companies on the scope and application of measures restricting the supply of goods and services, financing and technical assistance in relation to jurisdictions such as Russia, Iran, Syria and Libya
  • Advising clients in the financial services, manufacturing, telecommunications and energy sectors on the coordination of multi-jurisdictional investigations into alleged violations of economic sanctions and export control obligations and associated strategic advice in relation to engagement with relevant competent authorities
  • Advising a major international manufacturing company in the aerospace, energy and defence related sectors on the coordination of an internal investigation and handling of a voluntary self-disclosure to relevant export control and customs authorities for alleged violations of trade and customs regulations
  • Advising an international software developer and telecommunications company on product classification issues for the identification of export controlled hardware and software, compliance risk associated with distribution networks and cloud computing solutions and regulatory obligations associated with export authorisations, licensing conditions and regulatory reporting
  • Advising an international oil and gas development, exploration and production company on the management of third party risk associated with its sub-contractors, suppliers and customers and the drafting of appropriate contractual terms and conditions and representations and warranties