Over the past five years, an increasing percentage of our export control consulting work has been assisting law firms to address the needs of their clients. Typically, they provide the legal services and we support them with the expertise needed for commodity classification. This trend is increasing now as reform momentum gathers and the importance of the “600 series” looms large. Sometimes we do this work directly for the client after the law firm’s introduction; other times we work and bill through the law firms, using them as our conduit for client interaction. This work falls into three categories: commodity classification, compliance audits, and assistance on I-129 visa petition queries regarding deemed exports. Below we present anonymous CTP case studies describing our work for various law firms.
- A prominent law firm had provided extensive legal assistance to a mid-size electronics company but did not have the in-house resources to perform the necessary commodity classification task. The lawyers referred CTP to the client, and we completed the work under budget and ahead of schedule.
- A large immigration law firm sought our assistance with ongoing I-129 visa petition queries from a prominent international shipping company. We developed and refined a procedure that we have since used dozens of time for fast turnaround of these queries.
- The in-house counsel for a large international NGO (Non-Governmental Organization) sought an on-site Internal Assessment/Audit of their compliance policies, performance and risks in certain foreign countries, not just with export controls but also with OFAC (Office of Foreign Assets Control) embargo restrictions. CTP experts traveled to the domestic headquarters and four international locations to interview staff, review procedures, and audit records.
- The outside counsel for a large aerospace firm, embroiled in a high-profile arbitration involving delicate TAAs (Technology Assistance Agreements), requested that CTP’s licensing and legal specialists work with them to interpret challenges, identify risks, and write or review responding technical documentation.