He has an international practice representing clients on trade and regulatory enforcement matters, including export controls, economic sanctions, anti-bribery, and other laws governing cross-border transactions. Mike advises multinational companies from a wide range of industries, including financial services, defense and aerospace, manufacturing, life sciences, and energy and natural resources.
Mike’s practice is focused on the legal regimes that govern international trade, including:
- Sanctions administered by the Office of Foreign Assets Control (“OFAC”);
- Export controls, including the Export Administration Regulations ("EAR") and International Traffic in Arms Regulations ("ITAR");
- Foreign investment controls (“CFIUS”); and
- Foreign Corrupt Practices Act (“FCPA”).
Mike routinely represents clients in enforcement actions and investigations before OFAC, the Directorate of Defense Trade Controls (“DDTC”), the Bureau of Industry & Security (“BIS”), Customs and Border Protection (“CBP”), and other federal government agencies (Justice, Defense, Treasury, Homeland Security, Commerce, and others). He has represented clients in hundreds of regulatory enforcement matters, including voluntary disclosures, administrative proceedings, consent agreements, and agency-led investigations (subpoenas, directed disclosures, seizures and detentions).
He has handled some of the most significant matters before the Committee on Foreign Investment in the United States (“CFIUS”), including transactions requiring a variety of national security mitigation measures. His practice in this area includes representation on related regulatory requirements under the ITAR and National Industry Security Program, including representing clients before DDTC and the Defense Security Service (“DSS”).
Mike also provides advice on trade regulatory compliance programs and counsels clients on issues they may encounter in their efforts to comply with these laws. His experience in this area ranges from designing comprehensive and integrated compliance programs across the trade regulatory landscape (including, export controls, sanctions, FCPA, and anti-money laundering) to helping clients address significant hurdles to compliance, often with respect to managing risks in third party relationships and data management and information technology issues. He also provides day-to-day counselling on the requirements of these laws to a variety of market-leading companies in the aerospace, defense, commercial manufacturing, shipping, financial services, and life sciences industries.
Mike has served as a U.S. Government-approved external monitor with responsibility for oversight and monitoring activities subject to the ITAR, external audits, and a global corporate compliance program.
Prior to private practice, Mike clerked for the Fraud Section of the U.S. Department of Justice, Criminal Division, where he assisted FCPA prosecutions. He also clerked at the U.S. Attorney’s Office for the District of Columbia and the U.S. Court of Federal Claims. As a litigator, Mike tried more than two dozen jury and bench trials.