Covington & Burling LLP operates as a limited liability partnership worldwide, with the practice in England and Wales conducted by an affiliated
limited liability multinational partnership, Covington & Burling LLP, which is formed under the laws of the State of Delaware in the United States
and authorized and regulated by the Solicitors Regulation Authority with registration number 77071..
Co-chair of the firm’s International Trade Controls practice group, Kim Strosnider advises companies on the application of international trade controls, including export controls, economic sanctions, and antiboycott laws and regulations.
Kim counsels clients across a range of industries on trade control matters, including resolving complex compliance, enforcement, licensing, and jurisdiction/classification issues. She regularly advocates for clients before the key trade controls agencies, including the U.S. Departments of State, Commerce, and Treasury.
Kim has led numerous internal investigations for clients on trade controls matters, and has helped companies design and implement compliance programs. She also frequently advises on trade control issues in mergers, acquisitions, and divestitures.
Among the areas in which Kim counsels clients are compliance with the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), economic sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC), and antiboycott programs administered by the Commerce and Treasury Departments. She also advises on compliance with ATF regulations.
Kim also has represented clients in state and federal court litigation and before arbitration panels.
Led more than a dozen internal investigations on export control matters for a major U.S. aerospace manufacturing company, including designing and helping the company implement corrective actions.
Conducted global sanctions and export controls compliance risk assessments for a major non-U.S. natural resources company, and provide day-to-day advice to the company on global sanctions and export control issues.
Provide day-to-day counseling and advice to a U.S. oilfield services company on U.S. sanctions, export controls, and antiboycott compliance, including securing export licensing to support the company’s worldwide operations, providing training in U.S. trade controls compliance, developing policies and procedures, and successfully resolving an antiboycott voluntary disclosure.
Advise companies in the media, manufacturing, sports, and other sectors on Venezuela and Cuba sanctions and export control issues.
Led an internal investigation for a U.S. manufacturer relating to trade with Iran, including guiding the company on OFAC compliance issues and SEC reporting requirements.
Assisted a U.S. manufacturer in navigating U.S. defense trade and nuclear regulations with respect to a major project in China.
For more than five years, has advised a global services firm on compliance with the U.S. sanctions targeting Russia, including diligence with respect to the ownership and control of various business partners in hundreds of engagements in it has undertaken.
For an international company, successfully resolved a sanctions disclosure relating to North Korea, including conducting an internal investigation, drafting a voluntary disclosure, and engaging with the company’s auditors on the matter.
For a diversified U.S.-based manufacturing company, developed multi-jurisdictional compliance manuals covering its global operations that addressed export controls, sanctions, and antiboycott compliance, as well as anti-corruption compliance.
Represented dozens of clients in mergers and acquisitions activities, including conducting and responding to trade controls due diligence, crafting representations and warranties and other contractual provisions related to trade controls compliance, and filing M&A-related notifications with the State Department.
Successfully defended a $20 million trade-controls- related claim against a U.S. technology company related to the divestment of a business unit.
Counseled a non-U.S. company on U.S. and UN sanctions relevant to activities in Somalia.
Counsel numerous clients on the application of U.S. sanctions and humanitarian licensing programs for the provision of food, medicine, and medical devices to Iran, Syria, and Cuba, including providing guidance on general and specific licensing and the use of license exceptions.
Assisted client in obtaining Commerce Department licensing for export of drone technology to Africa.
Advised defense contractor on internal investigation related to an antiboycott compliance issue.