Ama A. Adams
Ama Adams’ practice focuses on international transactions and the U.S. government’s regulation of trade and investment. This includes most notably export controls, economic sanctions, anti-corruption and anti-money laundering, foreign direct investment and customs laws and regulations. She advises clients on these complex issues in a range of industries, including the financial services, aviation, biotechnology, life sciences, oil and gas, manufacturing, technology, and chemical sectors.
In addition to advising clients on the application of international trade regulations to their global business operations, Ms. Adams also assists clients in developing compliance programs, handling pre-and post-acquisition due diligence, conducting internal investigations relating to potential violations of trade laws and representing clients before the U.S. government agencies in connection with, license requests, enforcement matters, and government inquiries. She also advises clients on cross-border investment and national security matters, including national security reviews and investigations before the Committee on Foreign Investment in the United States (CFIUS). Ms. Adams has successfully represented a number of foreign and domestic clients through the CFIUS clearance process and regularly advises clients on managing CFIUS risks across investment scenarios.
- Successfully procured a license authorization from OFAC for continued wind-down operations for a German market research company following the revocation of General License H.
- Conducting an internal investigation for a non-U.S. financial institution in connection with potential transactions involving several U.S. correspondent banks and sanctioned countries.
- Advising a global private equity firm with an internal investigation into potential violations of Iran sanctions regulations.
- Supervised a pre-closing sanctions compliance diligence and systems review and post-closing trade compliance systems integration of export control and sanctions compliance systems in multiple jurisdictions for two major multinational oilfield services and supply companies.*
- Prepared voluntary disclosures related to potential violations of U.S. sanctions programs, including the hiring of sanctioned country nationals, prohibited dealings with Specially Designated Nationals, and the transfer of goods and technology to sanctioned countries for clients in various industries, including energy, aviation, telecommunications, chemical, manufacturing and coatings companies.*
- Performed risk assessments on export control compliance for the portfolio companies of the world’s largest investment funds, including those in the software development, artificial intelligence, chemicals, manufacturing and energy services industries.
- Performed a global risk assessment on export controls, sanctions and anti-corruption program for a multinational energy corporation involved in over 30 jurisdictions around the world, including the development of risk mitigation plans and protocols.
- Performed a comprehensive deemed export risk assessment of a multinational biopharmaceutical company, including a review of the company’s technology control plan, classification procedures, human resources policies and intra-company system processes.
- Obtained a favorable resolution with BIS in connection with a voluntary disclosure of certain exports of equipment by a U.S. biotechnology product development company in connection with the Russia/Ukraine and Crimea sanctions regulations.
- Advised a specialty biopharmaceutical company on the export requirements for pharmaceuticals in connection with product shipments to over 50 jurisdictions around the world, including provided training sessions on U.S. export controls for legal and compliance personnel.*
- Conducted a comprehensive due diligence review of the export control compliance programs of a large aircraft part supplier in connection with its acquisition by another company, which involved a review of compliance procedures with respect to the EAR and ITAR.*
- Assisted a major U.S. airline to become one of the first companies in that industry to gain admission into the Customs and Border Protection Importer Self-Assessment Program, which included a review of the company's existing import compliance policies and procedures and providing counseling with respect to a full range of import issues.*
- Advised a major U.S. chemical company regarding the requirements to become certified under CTPAT Program; assisted client in preparing CTPAT application; advised client in connection with CTPAT verification process.*
- Successfully defended a large U.S. apparel manufacturer in connection with ICE and CBP investigation of textile imports under NAFTA, which resulted in the dismissal of fraud charges and a settlement with no civil penalties.*
- Represented a Hong Kong-based technology company in connection with its acquisition of a U.S.-based semiconductor advanced packaging business.
- Represented a German headquartered copper manufacturer in connection with its acquisition of a leading, value-added converter, fabricator, processor and distributor of specialized non-ferrous products in North America.
- Represented the only U.S. producer of platinum and palladium in its acquisition by a Russian metal company.*
- Represented a large non-U.S. exploration company in connection with its acquisition of a U.S. navigation company.*
- Represented a major U.S. chemical company in its acquisition of a U.S.-based subsidiary of a state-owned company based in the Middle East.*
Foreign Corrupt Practices Act
- International oilfield services company – pre- and post-acquisition anti-corruption diligence and systems review of major multinational oilfield services and supply
company with operations in multiple countries.*
- Multinational airline parts supplier – due diligence review of the FCPA and export control compliance program in connection with its acquisition by another company.*
- U.S. energy companies – preparation of FCPA due diligence materials and counsel on the implementation of FCPA safeguards for foreign joint venture operations.*
- Co-author, “INSIGHT: Mid-2019 CFIUS Review—The ‘Calm’ Before the Storm,” Bloomberg Law (July 11, 2019)
- Co-author, “A Dramatic 6 Months For OFAC Sanctions Enforcement,” Law360 (June 28, 2019)
- Quoted, “OFAC sanctions guidance is a 'toolkit for compliance',” International Financial Law Review (May 28, 2019)
- Co-author, “Key Takeaways From OFAC’s Compliance Program Guidance,” Law360 (May 28, 2019)
- Co-author, “INSIGHT: Why Am I Receiving New Questions About My Firm’s Anti-Money Laundering Program?,” Bloomberg Law (May 1, 2019)
- Quoted, “Cfius takes bold move into enforcement with mitigation fine,” International Financial Law Review (April 26, 2019)
- Co-author, “OFAC Is Raising The Compliance Bar,” Law360 (April 3, 2019)
- Quoted, “OFAC designation of Russian bank a warning to Maduro's supporters,” International Financial Law Review (March 25, 2019)
- Editor, The Practitioner’s Guide to Global Investigations, Volume I: Global Investigations in the United Kingdom and the United States, Third Edition (2019)
- Quoted, “PRIMER: US and EU sanctions against Russia,” International Financial Law Review (December 17, 2018)
- Co-author, “A Review Of US Economic Sanctions in 2018,” Law360 (December 11, 2018)
- Co-author, “Société Générale: Sanctions Enforcement Is Alive And Well,” Law360 (November 30, 2018)
- Quoted, “The New Wave of Protectionism,” Mergermarket (October 16, 2018)
- Co-author, “CFIUS Pilot Program: Immediate Investment Implications,” Law360 (October 15, 2018)
- Co-author, “US' Secondary China Sanctions Signal New Risks For Cos.,” Law360 (September 26, 2018)
- Co-author, “US sanctions and export controls: What every healthcare and life sciences compliance officer needs to know,” WorldECR (September 2018)
- Quoted, “3 Takeaways From New Export Control Act,” Law360 (September 14, 2018)
- Co-author, “Iran Sanctions Snapback: Practical Implications and Compliance Considerations for Japanese Companies,” Japan Institute of Business Law (August 23, 2018)
- Quoted, “Primer: Russian sanctions: a steady wave,” International Financial Law Review (July 16, 2018)
- Quoted, “European finance departments brace for new Iran sanctions,” Financial Management (July 9, 2018)
- Quoted, “Primer: US and EU Sanctions against Russia,” International Financial Law Review (June 21, 2018)
- Co-author, “Mid-2018 Sanctions Review: A Turbulent Year So Far,” Law360 (June 21, 2018)
- Co-author, “How Iran Deal Pullout Will Impact Cos. And Investors,” Law360 (May 9, 2018)
- Quoted, “Complex Choices Await World if Trump Exits Iran Nuclear Deal,” Associated Press (May 4, 2018)
- Quoted, “Ofac: Venezuela's crypto offering could be sanctions breach,” International Financial Law Review (March 1, 2018)
- Quoted, “Targeted sanctions help US maintain financial influence abroad,” International Financial Law Review (February 22, 2018)
- Co-author, “A Review Of US Economic Sanctions In 2017,” Law360 (December 20, 2017)
- JD, University of Virginia School of Law, 2001
- BA (French & History), Wesleyan University, 1996