Leading the firm’s Sanctions + Trade Controls team, Pete has deep experience in export controls, economic sanctions, and related areas. His practice includes regulatory counseling, compliance program development and enhancement, assistance with M&A and other complex transactions, responding to government inquiries, conducting internal investigations, advising on voluntary self-disclosures, and providing robust representation in civil and criminal enforcement actions. For example, Pete assists with obtaining authorizations for otherwise restricted trade and investment transactions, foreign national employees with access to export-controlled technology, and other common requirements. He advises on risk assessments, know-your-customer (KYC) and due diligence best practices, contractual safeguards, jurisdiction and classification determinations for potentially export-controlled products and technologies, and many other practical compliance steps. For non-U.S. companies, he offers clear insights on the extraterritorial reach of these U.S. laws, and how they can be enforced abroad. Pete also assists clients seeking removal from (or concerned about possible designation on) a variety of U.S. government sanctions lists, including the Specially Designated Nationals (SDN) list, the Entity List, and others.

Pete’s experience covers the following areas in particular:

• The Export Administration Regulations (EAR), administered by the Commerce Department’s Bureau of Industry and Security (BIS);
• The International Traffic in Arms Regulations (ITAR), administered by the State Department’s Directorate of Defense Trade Controls (DDTC);
• The Part 810 nuclear export control regulations, administered by the Department of Energy’s National Nuclear Security Administration (NNSA);
• The economic sanctions programs of the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State;
• The Foreign Corrupt Practices Act (FCPA);
• The Information and Communications Technology and Services (ICTS) program, also administered by BIS at Commerce;
• The BIS anti-boycott regulations;
• The munitions import regulations of the Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and Explosives (ATFE);
• The Department of the Treasury’s Outbound Investment Security program and the Committee on Foreign Investment in the United States (CFIUS);
• Anti-money laundering (AML) laws and regulations; and
• The Bulk Sensitive Personal Data and U.S. Government-Related Data regulations, administered by the Department of Justice’s National Security Division.

In these highly technical and sensitive areas, clients look to Pete for his practical, business-centric approach. His focus on each client’s unique circumstances, including size, risk profile, and business priorities, allows him to provide tailored solutions to mitigate risk, while maintaining smooth global operations, and looking for opportunities to expand markets where possible. With an in-depth understanding of U.S. government policies and priorities, he guides clients on targeting the most critical risks they face, while seeking simplicity in lower-risk areas.

Pete represents clients in both heavily regulated industries and those that are historically less exposed to these issues, including aerospace and defense, technology, financial services, manufacturing and industrial, telecommunications, agriculture, health care and biotechnology, energy, metals and mining, and space. He has extensive experience with cross-border regulatory compliance matters involving Russia, China, Hong Kong, India, Ukraine, Cuba, Venezuela, Iran, Central Asia and the Caucasus, Myanmar (Burma), Lebanon, Syria, Libya, Iraq, Pakistan, Sudan, Afghanistan, Belarus, Yemen, Mexico, Colombia, Nicaragua, the Democratic Republic of the Congo, Zimbabwe, and others.

In his pro bono work, Pete advises nonprofit organizations on how to operate in sanctioned countries and similarly high-risk areas, including North Korea.

• Counseling a U.S.-based manufacturing company on export controls and sanctions matters arising throughout its global business, including assisting with numerous voluntary self-disclosures, and guiding large-scale reevaluations of product classifications both internally and through commodity jurisdiction and classification (CJ and CCATS) requests.
• Guiding a U.S. company in seeking what may be the first ever OFAC authorization to import state-produced commodities from a particular embargoed country into the U.S.
• Assisting civil nuclear power companies in compliance with U.S. export controls applicable to the industry.
• Helped obtain a DOJ declination and no action from BIS following criminal and civil investigations into suspected export control violations by a U.S.-based global electronics company.
• Conducted a global ITAR audit of a major European aerospace company’s commercial and defense-related businesses.
• Counseled a China-based global technology company on complex U.S. export controls and sanctions issues, and other national security regulatory matters.
• Provided a comprehensive U.S. export controls and sanctions risk assessment and compliance program gap assessment to a publicly traded, U.S.-based vehicle manufacturer.
• Helped close an acquisition of a large, UK-based global satellite and maritime technology company that had been held up due to highly complex sanctions issues.
• Identified critical export control issues in a U.S.-based technology company’s proposed acquisition of a non-U.S. entity with high-risk business in China.
• Advised U.S. and global private equity and other fund managers on regulatory and geopolitical issues and trends.
• Advised a U.S.-based hedge fund on sanctions compliance considerations in seeking large-scale new business opportunities relating to Venezuelan debt instruments.
• Assisted a large Latin American mining company in developing and implementing an enhanced sanctions and export controls compliance program and in evaluating and managing high-risk global transactions.
• Assisted a U.S. video surveillance company in assessing and addressing supply chain risks relating to parties subject to export controls and sanctions restrictions.
• Advised a U.S. telecommunications company considering a variety of ambitious business activities in and related to Cuba on economic sanctions and export control issues.
• Helped a Southeast Asian energy company obtain OFAC authorizations for large-scale projects with a U.S.-sanctioned partner.
• Advised a Bahraini company on managing risks while seeking to extricate itself from complex relationships with sanctioned parties.
• Assisted a Canadian company in obtaining OFAC and BIS licenses for medical equipment sales to Cuba.
• Advised U.S.-based entities on ITAR brokering issues in connection with supplying U.S. partner forces.
• Represented a Myanmar-based individual and related business entities seeking removal from OFAC’s SDN list.
• Represented individuals sanctioned by OFAC under the Kingpin Act for alleged money laundering activities in Lebanon and South America and obtained their removal from the SDN list.
• Represented a UAE-based individual in seeking removal from the SDN list following allegations relating to the oil and shipping sectors.
• Counseled a major European oil and gas company with large investments in an embargoed country with both day-to-day and strategic U.S. legal compliance issues.
• Advised a Southeast Asian food company on sales to Iran in compliance with sanctions.
• Helped conduct anti-corruption investigations involving mining activities in Pakistan, Indonesia, and the Democratic Republic of the Congo, and related resolution proceedings with the SEC and DOJ.
• Advised a large emerging U.S. defense contractor on anti-corruption and EAR / ITAR (including Part 130) issues in expanding into new markets and acquiring new entities.
• Advised a UK-based emerging defense contractor on U.S. market entry considerations relating to export controls.

• Legal 500 U.S., Rising Star, International Trade: Customs, Export Controls and Economic Sanctions (2023-2024)
• Legal 500 U.S., Rising Star, Dispute Resolution: International Trade (2021-2022)
• Exceptional Civilian Service Award, U.S. Department of Defense (2009)
• Joint Civilian Service Commendation Award, U.S. Transportation Command (2009)