Business & Government

Economic Sanctions & Export Controls

United States law authorizes the President to impose trade embargoes and economic sanctions on foreign countries and their nationals for foreign policy and national security reasons. These rules, which are primarily administered and enforced by the Treasury Department's Office of Foreign Assets Control (OFAC), are extremely complex, constantly evolving, and far-reaching in terms of their overseas application. Mowry & Grimson attorneys have substantial experience in assisting clients in complying with U.S. trade embargoes and economic sanctions programs involving countries such as Cuba, Iran and North Korea. Mowry & Grimson attorneys have worked directly with OFAC, both in obtaining licenses for specific client transactions and in negotiating settlements with respect to potential enforcement actions. We have also assisted U.S. and foreign companies in establishing effective compliance programs to adhere to U.S. trade sanctions against designated countries and their nationals.

The U.S. government also imposes export controls, or licensing requirements, on exports of dual-use goods, technology and software to other countries. Mowry & Grimson attorneys have extensive experience in assisting U.S. and foreign manufacturers in navigating the complex web of U.S. export control laws and in obtaining export licenses from the U.S. Department of Commerce and U.S. Department of State. Mowry & Grimson attorneys have also defended companies against U.S. government enforcement actions alleging violation of U.S. export control laws and assisted companies in filing voluntary disclosures with the government. Mowry & Grimson attorneys have counted U.S. electronics, technology and medical device manufacturers, as well as universities and insurance companies, among their clients.


Mowry & Grimson offers counsel to clients in matters involving the Foreign Corrupt Practices Act (FCPA). The FCPA generally prohibits direct or indirect payments, offers of payments or promises of payments, to a foreign government official or a foreign political party, official or candidate made for the corrupt purpose of influencing an official foreign governmental act or decision. The FCPA also requires publicly traded companies to comply with its accounting and recordkeeping provisions. Mowry & Grimson attorneys have advised clients on the FCPA's applicability to proposed international business transactions and activities. We have also assisted clients seeking to minimize potential liability stemming from the acts of third parties, such as agents and distributors and counseled corporate clients to develop and implement effective FCPA compliance programs. We have conducted, or advised clients undergoing, FCPA due diligence interviews and pre-merger/acquisition discovery and disclosures in both U.S. and foreign countries.

Market Access

The WTO and free trade agreements are intended to expand market access opportunities for private companies, but sometimes companies still encounter unfair or illegal trade barriers both at home, as importers, and abroad when trying to break into foreign markets. Mowry & Grimson advises U.S. and foreign companies and non-governmental organizations on a wide range of issues targeted to specific global regions. Partnered with local firms, Mowry & Grimson's past efforts have included advising companies on U.S.-South Africa trade policy, South American customs laws and the impact of regional free-trade agreements. Mowry & Grimson can identify promising foreign markets, devise entry strategies, and craft solutions to market obstacles, all with the aim of helping our clients achieve their business objectives. To that end, we provide legal, business and political advice, intelligence, and representation in capitals around the globe.

Sanitary and Phytosanitary Measures

Sanitary and phytosanitary (SPS) measures affect food and farm product trade, both in the United States and abroad.  Governments apply SPS measures to protect human, animal and plant life and health from a variety of dangers, including pests and diseases, dangerous food additives, contaminants, toxins and organisms.  Governments change SPS requirements often in response to emerging threats.  Mowry & Grimson attorneys assist clients in navigating domestic and international SPS requirements and assuring compliance with related health and safety standards.