Alexandre (Alex) Lamy

Biography

Alexandre (Alex) Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Alex contributes regularly to Baker McKenzie's Sanctions & Export Controls Update blog.

Alex has been the sole US winner of the Lexology Client Choice Award for the "Trade & Customs" category in 2021 and 2022. He was recognized in Who's Who Legal 2022 Edition of its Global Guide to Trade & Customs Lawyers "for his outstanding performance facilitating clients on sanctions, export controls and compliance checks." In 2020, the same publication recognized Alex as a "leading individual" in North America on International Sanctions and the publication reported that he "attracts applause for delivering 'a practical service which understands the needs of the business'. His 'ready availability to clients, thorough research and strong presentation skills' are further acclaimed." He was also recognized in the 2019 Edition of the same publication as being "much sought after by clients who praise his 'advice of the highest quality' and add, 'He is technically very good on OFAC sanctions issues and military/dual use export controls.'" Finally, Alex was named by Financier Worldwide in “POWER PLAYERS: International Trade & Sanctions 2021 - Distinguished Advisers."

Between August 2021 and August 2023, Alex was the co-chair of the ABA Section of International Law’s Export Controls & Economic Sanctions Committee. Prior to that appointment, he served on the steering group and as a Vice Chair of the Committee, starting back in August 2011. Alex has organized multiple events regarding recent developments in US trade sanctions and export controls for the Committee.

Practice Focus

Alex advises clients on compliance with US export controls, trade and economic sanctions, export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and antiboycott controls. He advises US and non-US companies in the context of licensing, enforcement actions, internal investigations, compliance audits, mergers and acquisitions and other cross-border transactions, and the design, implementation, and administration of compliance programs. Alex has negotiated enforcement settlements related to both US sanctions and the EAR as well as delistings from US sanctions. He also works with clients on issues related to the Government's Committee on Foreign Investment in the United States (CFIUS) with respect to the acquisition of US enterprises by non-US interests.

Representative Legal Matters

Advise companies on various compliance issues related to sanctions programs administered and enforced by the Office of Foreign Assets Control (OFAC), including US sanctions targeting Russia/Crimea, Iran, Cuba, North Korea, Syria, Venezuela, the Sectoral Sanctions Identifications List, Non-SDN Menu-Based Sanctions List, and Specially Designated Nationals (SDNs).
Counsel companies on compliance with US secondary sanctions including those targeting Russia/Crimea, Iran, North Korea, and Syria.
Advise companies on compliance with US export controls under the ITAR and EAR.
Negotiated with OFAC to have US sanctions lifted from Nynas AB (2020).
Negotiated with OFAC and the Bureau of Industry and Security (BIS) to reach a global enforcement settlement involving apparent violations of US sanctions targeting Iran by US and UAE subsidiaries of a European company (2021).
Negotiated with BIS to reach an enforcement settlement involving apparent violations of US export controls by the US subsidiary of a European company (2020).
Negotiated with OFAC to reach an enforcement settlement involving apparent violations of US sanctions targeting Iran by a Turkish subsidiary of a US-based company, which involved the first designation of a Foreign Sanctions Evader as part of the enforcement resolution (2019).
Advise European bank on Russia sanctions investigations conducted by OFAC and US Department of Justice.
Conduct investigations into sanctions and export-control compliance for US and non-US companies.
Counsel companies on the implications of US sanctions and export controls related measures in non-US acquisitions.
Assist companies regarding responses to various US state divestment measures related to Iran, Sudan, and Cuba.
Provide compliance advice to companies with respect to US export controls and trade sanctions, including drafting and submitting license applications and classification requests to OFAC, BIS, and the Directorate of Defense Trade Controls (DDTC).
Advise clients on preparing and drafting disclosures to OFAC, BIS, and DDTC.
Conduct gap assessments of compliance programs with respect to sanctions and export controls.
Counsel clients on submissions to the US Government's Committee on Foreign Investment in the United States (aka CFIUS) with respect to the acquisition of US enterprises by non-US interests, including changes resulting from the Foreign Investment Risk Review Modernization Act (aka FIRRMA).

Professional Honors

Lexology Client Choice Award 2021 & 2022 for the "Trade & Customs" category (US sole winner)
Recognized in Who's Who Legal's Global Guide to Trade & Customs Lawyers - International Sanctions (2019-2022)
Recognized by Financier Worldwide in "POWER PLAYERS: International Trade & Sanctions 2021 - Distinguished Advisers"

Professional Associations and Memberships

American Bar Association - Member
Virginia State Bar Association - Member
District of Columbia Bar - Member

Admissions

District of Columbia~United States (2010)
Virginia~United States (2009)

Education

University of Virginia School of Law (JD) (2009)
Claremont McKenna College (BA, magna cum laude) (2000)

Languages

English
French

Publications

Co-author, "US Sanction Investigations Journey Through Agencies and Courts," Bloomberg Law, 5 September 2023
Co-author, "Minimizing Discrimination Risks in Export Control Compliance," Law360, 16 May 2023
Author, "Demystifying OFAC and BIS Civil Settlement Negotiations," Law360, 13 September 2022
Author, "OFAC Should Issue SDN Payment Licenses that Don't Expire," Law360, 21 April 2021
Author, "A New Approach To OFAC's Rejected-Transactions Reporting," Law360, 21 May 2020
Co-author, "Anatomy of an export control investigation," in The Export Compliance Manager's Handbook (WorldECR), 2d ed., 2020

Co-author, "How BIS Will Review Emerging Technology Export Controls," Law360, 19 December 2018
Co-author, "Policy Is Changing For Technology Transfers," Law360, 20 June 2018
Co-author, "Trade and Financial Sanctions and Export Controls," in A Practitioner's Guide to The Law and Regulation of Financial Crime (2d ed.), 2018
Co-author, "International Activities," in Corporate Legal Compliance Handbook (Wolters Kluwer), 2016
Co-author, "Five Ways a Company Can Leverage Its Anti-Bribery Compliance Programto Facilitate Sanctions Compliance," FCPA Report, vol. 5, No. 18, 14 September 2016
Co-author, "An Overview of the Taxation of US Investment Into Cuba," Tax Notes International, 20 June 2016
Co-author, "Cuba Sanctions Relaxation: A Cautionary Tale for Non-US Subsidiaries," Risk & Compliance Magazine, June-September 2015
Author, "Managing Sanctions Compliance Challenges," Risk & Compliance Magazine, June-September 2015
Co-author, "Anti Corruption Compliance and the Russia/Ukraine Sanctions," Risk & Compliance Magazine, October/December 2014
Co-author, "The 'too big to jail' Environment: How Financial Institutions Have Run Afoul of US Money Laundering and Sanctions Regulations," Compliance Officer Bulletin, November 2013
Co-author, "State and Local Divestment Measures: A Growing US Trade Compliance Concern," Bloomberg Law, 8 March 2013
Co-author, "Export Compliance Programs: What Export Enforcement Investigations Commonly Reveal," Compliance & Ethics Professional, November/December 2012
Co-author, "Doing Business with Iran: New UN, EU and US Measures Imposed Toughest Sanctions Yet," International Trade Law & Regulation, Vol. 16, Issue 5, 2010

Presentations

Presenter, "US Export Control Developments in 2022," Houston Energy Industry Trade Compliance Association/International Compliance Professionals Association (Houston, TX), December 2022
Presenter, "US Export Controls Targeting China," International Compliance Professionals Association Fall Conference (Dallas, TX), October 2022
Co-speaker, "Qué esperar en materia de comercio exterior en América Latina como respuesta a la coyuntura política-económica mundial," AmCham Peru webinar, May 2022
Speaker, "Sanciones comerciales de Estados Unidos a Rusia y su impacto para las filiales locales," AmCham Argentina webinar, April 2022
Co-speaker, "Sanctioning Russia: What You Need to Know," AmCham China webinar, March 2022
Co-speaker, "Examining U.S. Export Controls and the Laws of the World Trade Organization," Lexology webinar, December 2021
Co-speaker, "Practical Overview of Regulatory Landscape for China Trade & Sanctions," ACI "Ensuring Compliance with U.S. and China Economic Sanctions" Virtual Conference, September 2021
Co-speaker, "Keeping supply chain risks at bay: A healthcare & life sciences view," Global Healthcare & Life Sciences Webinar Series, April 2021
Co-speaker, "United States: Avoiding the Entity List - Rise of trade secrets enforcement risk through US export controls," Baker McKenzie InsightPlus, March 2021
Moderator and Speaker, "US Sanctions Year in Review," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, 2012-2021 (annual event)
Moderator and Speaker, "US Export Controls Year in Review," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, 2013-2021 (annual event)
Speaker, "Webinar on Executive Order 13959, China Blocking Rule, and Related Developments," Hong Kong Investment Funds Association, January 2021
Panelist, "International regulation and the impact of sanctions on trade finance activities and "Tales from the Trenches: What are the issues and concerns facing banks and their customers," Institute of International Banking Law & Practice, 2019 Annual Trade Finance Compliance Conference, New York, NY, November 2019
Moderator, "New Era for the Helms-Burton Act and the Canadian and EU Blocking Statutes," ABA Section of International Law, Export Controls and Sanctions Committee, Washington, DC, June 2019
Panelist, "Emerging Trends and Issues in US Sanctions: Effects of Primary and Secondary Sanctions on Cross-Border Business," Global Legal Alliance Annual General Meeting, Washington, DC, October 2018
Speaker, "BIS/OFAC – A Practical Discussion," NGO Counsel Forum, New York, NY, October 2018
Moderator, "New US Sanctions Targeting Russia Under the Countering America's Adversaries Through Sanctions Act (CAATSA)," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, November 2017
Speaker, "Global Trade Sanctions and Regulatory Compliance; Why Does It Matter to Me?", GBTA Energy, Resources & Marine Symposium, Houston, TX, November 2017
Panelist, "US Domestic and International Estate Planning and Protection," Iranian American Bar Association, New York, NY, November 2016
Panelist, "International Franchising in Challenging Times and Places," American Bar Association Franchising Forum, Miami, FL, November 2016
Moderator, "Russian Response to Western Sanctions: Countersanctions and Their Impact," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, November 2015
Moderator, "The US, EU, and UN Sanctions Implementation of the Iran Joint Comprehensive Plan of Action," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, August 2015
Speaker, "Update on Russia and Ukraine Trade Sanctions Briefing," Chicago Bar Association, April 2014
Moderator, "US and EU Sanctions Implementation of the Iran Joint Plan of Action," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, February 2014
Moderator and Speaker, "Iranian Transactions and Sanctions Regulations," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, December 2012
Moderator and Speaker, "OFAC Facilitation: Know It When You See It?", ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, November 2012
Moderator, "New Economic Sanctions Against Syria: US, Canadian, and EU Approaches," ABA Section of International Law, Export Controls and Economic Sanctions Committee, Washington, DC, November 2011
Speaker and Panelist at various Baker McKenzie conferences focused on trade compliance issues in US and European offices, 2011-present