David “Dj” Wolff

Partner, Crowell & Moring, and
CMI Director

djwolff@crowell.com

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate

At Crowell & Moring, he practices in the International Trade practice group where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations, including by providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws which can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.

Dj also works as a director with Crowell & Moring’s affiliate, C&M International, where he assists clients with international market access issues and represents clients through the multinational negotiation and national implementation of treaties, as well as in the development and advancement of initiatives through the Asia-Pacific Economic Cooperation (APEC) Forum.

Dj was selected as one of The National Law Journal’s “DC Rising Stars” in 2019, and was identified as one of the “Future Leaders” by Who’s Who Legal: Investigations in 2018 and 2019. He is an Acritas Star, Acritas Stars Independently Rated Lawyers (2019), and named one of the “40 under 40” in Investigations internationally by Global Investigations Review in 2017. Dj was one of the five finalists for the WorldECR Young Practitioner of the Year award in 2016.

Recent significant matters:

Economic Sanctions Counselling

• Secured successful closure of OFAC subpoena without penalty relating to a review of U.S. service provider’s compliance with Russia-related “sectoral” sanctions.
• Conducted week-long intensive sanctions training for more than 300 bank compliance officers in four countries on three continents over the course of three months.
• Implemented sanctions-screening system for U.S. manufacturer’s global operations, including designing the internal policies and procedures, training the internal compliance teams, and managing the review, escalation, and disposition of potential matches.
• Seconded to EU based financial institution’s branch office in Dubai to serve as in-house sanctions counsel providing daily guidance on sanctions-related compliance and investigation matters.
• Represented, including through direction of local counsel across three jurisdictions, a multinational manufacturer in response to a criminal inquiry from the Russian customs authority related to exports to Russia.
• Served, in collaboration with a U.K. colleague, as expert witnesses related to U.S. and U.K./EU economic sanctions, in litigation in Scotland, on behalf of a Scottish firm, related to the largest professional negligence claim ever filed in Scotland.
• Seconded to federally-regulated U.S. financial institution as its Global Economic Sanctions Compliance Leader responsible for overseeing a worldwide economic sanctions compliance program and a team of experts covering numerous third country subsidiaries and millions of annual transactions and customers.
• Led internal investigation for a U.S. manufacturer of activity undertaken by a newly acquired subsidiary in potential violations of U.S. and EU economic sanctions and export controls involving a team of lawyers in the U.S., United Kingdom, and Brussels.
• Collaborated with U.S. and EU data privacy colleagues to represent a non-U.S. subsidiary of a U.S. financial institution in a petition to the French Data Privacy authority for authorization to conduct screening for sanctions compliance against certain types of personal identifying information.
• Represented U.S. manufacturer of equipment used in refineries and downstream oil and gas facilities in reviewing all potential transactions for compliance with U.S. and EU blocking and sectoral sanctions on Russia.
• Represented a multinational publishing company with respect to the scope of the exemptions and authorizations related to informational material and publishing services for countries subject to U.S. embargo.
• Assisted in the internal review and development of a prospective trade compliance plan for a multinational service provider’s back-office support for its non-U.S. customers potentially doing business in sanctioned countries.
• Conducted due diligence on a potential target company’s compliance with U.S. economic sanctions and export controls on behalf of a U.S. private equity firm in a successful $1.4 billion acquisition.

Export Controls & Antiboycott

• Represented a U.S. manufacturer in negotiations with the Bureau of Industry and Security (BIS) and Customs and Border Protection (CBP) to secure release of oil and gas equipment improperly seized before export to Russia.
• Secured commodity jurisdiction determination from the Department of Defense Trade Controls (DDTC) for a U.S. manufacturer to confirm its product was not subject to the International Traffic in Arms Regulations (ITAR).
• Prepared a series of commodity classification requests (CCATS) for a U.S. manufacturer.
• Represented a U.S. financial institution in an internal investigation and voluntary disclosure to the U.S. Commerce Department of potential violations of the U.S. antiboycott regulations.
• Prepared quarterly and annual antiboycott reports for the Commerce Department and the Treasury Department for U.S. manufacturer.

Import, Customs, and Trade Preference Program Implementation

• Represented a multinational well services provider in a successful Court of International Trade (CIT) litigation and Federal Circuit appeal to overturn CBP’s proposed customs classification and secure duty-free treatment of an imported product, resulting in millions in duty savings.
• Represented a U.S. consumer goods company in a petition to add new products to the list of those eligible for duty free importation under the Generalized System of Preferences (GSP).
• Represented a U.S. chemical manufacturer in a global review of its supply chain to optimize usage of U.S. and non-U.S. free trade agreements (FTAs) including NAFTA and KORUS and regional free trade agreements (RTAs) including those negotiated by ASEAN.

International Trade Policy and Multilateral Institutions

• Represented a wide range of U.S. associations in developing and advancing public-private initiatives in the Asia-Pacific Economic Cooperation Forum (APEC), including in-person meetings in China, Indonesia, Papua New Guinea, Peru, the Philippines, and Vietnam.
• Represented a U.S. trade association in negotiations with the European Commission regarding market access and regulatory cooperation aspects of the potential Trans-Atlantic Trade and Investment Partnership (TTIP).
• Represented a trade association during negotiating sessions of the World Intellectual Property Organization (WIPO) Intergovernmental Committee on Intellectual Property and Genetic Resources, Traditional Knowledge and Folklore.
• Coordinated a “roadshow” and in-person meetings for a U.S. trade association in countries party to the Trans-Pacific Partnership (TPP) during the TPP’s negotiations.

Pro Bono

• Represented a non-profit in securing the first-ever public exemption granted by the United Nations Security Council’s 1718 Committee from North Korea related sanctions to a non-UN affiliated body.
• Secured OFAC and BIS licenses for U.S. non-profit to undertake multi-drug resistant tuberculosis treatment involving U.S. persons and U.S. products in North Korea.
• Prepared training on compliance with U.S. sanctions, export controls, and anti-corruption legislation for a U.S. non-profit providing in-person tuberculosis and AIDS treatment around the world.
• Argued in front of the D.C. Circuit as amicus appointed by the Court in support of a D.C. inmate’s suit for damages against U.S. Parole Commissioners
• Represented DC inmate in Innocence Project motions and subsequent parole board hearings, ultimately resulting in the client’s successful release on parole.
• Coordinated C&M’s weekly tutoring program for the Thurgood Marshall Academy, a charter high school with a pre-law focus based in Anacostia.