Alison provides full-spectrum compliance counseling in the areas of export controls and sanctions, including under the US Export Administration Regulations and the OFAC sanctions. Her services include compliance planning, risk assessments, licensing, regulatory interpretations, voluntary disclosures, enforcement actions, complex internal investigations and audits, mergers and acquisitions and other cross-border activities. She also develops compliance training, codes of conduct, compliance procedures and policies.
She has particular experience in the following sectors: financial services, technology/IT services, travel/hospitality, telecommunications, semiconductors and manufacturing.
Representative Legal Matters
- Counseled numerous multinationals, including in financial services, travel technology, hospitality, software/SaaS and consumer goods, on mitigating multi-jurisdictional compliance risks in high-profile exits from the Russian market following the invasion of Ukraine.
- Successfully settled significant OFAC enforcement matter for air travel technology company for alleged violations of anti-terrorism sanctions, including resolution of novel and complex issues surrounding access to US software solutions and services.
- Advised various social media, content delivery and e-commerce platforms on establishing risk-based compliance programs and addressing compliance issues.
- Advised various software developers on encryption and export classification issues in the areas of mapping and location, network security, data visualization and payment technologies.
- Assisted European airline in overcoming regulatory hurdles to enable resumption of Iran route following the Joint Comprehensive Plan of Action with Iran, including proactively advocating regulatory changes and licensing policy to US regulators.
- For private equity fund, assessed and mitigated sanctions compliance and political risks associated with acquisitions in the aviation services sector, including conducting cross-border acquisition due diligence, obtaining time-critical licenses and conducting a pre-closing compliance investigation and voluntary disclosure alongside seller's counsel.
- Conducted multi-jurisdictional risk assessment and advised on exit strategies for consumer goods manufacturer in context of increasing international sanctions against North Korea.
- Represented numerous clients before the US Departments of Commerce and Treasury in export control and sanctions matters, including voluntary self-disclosures, responding to administrative subpoenas and other enforcement inquiries, licensing, classification requests, advisory opinions, and regulatory interpretations.
- Counseled international hospitality company on compliance risk assessments and compliance planning in preparation for corporate restructuring and IPO.
- Conducted deemed export compliance review for major telecommunications company.
- Advised on multiple encryption technical reviews under the US Export Administration Regulations for various software and IT companies.
Professional Associations and Memberships
- The Law Society of England and Wales
- American Bar Association, International Law Section
- California Bar International Law Section
- Women in International Trade - Northern California
- District of Columbia~United States (2013)
- California~United States (2002)
- England & Wales~United Kingdom (1998)
- College of Law at London (1996)
- Hosei University, Tokyo (1994)
- Cambridge University (M.A. Hons) (1994)
- Cambridge University (B.A. Hons, First Class, Oriental Studies) (1992)
- Washington, DC
- Contributor - World Economic Forum Insight Report Mapping TradeTech: Trade in the Fourth Industrial Revolution (December 2020)
- Presenter - Tech Talk (2015 and 2016)
- Presenter - Immigration and Export Control (California State Bar, 2011)
- Contributor - Cross-Border Transactions Handbook (Baker & McKenzie LLP, 2008)
- Presenter - EU Export Controls and Trade Sanctions (Export Control Coordinators Association of National Laboratories, 2006)
- Co-author - International Trade Chapter of The Encyclopedia of Information Technology Law (Sweet & Maxwell Ltd., 2005)