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, foreign direct investment and customs laws and regulations.
In addition to advising clients on the application of international trade regulations to their 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 represents companies before the Committee on Foreign Investment in the United States (CFIUS) in reviews under the Foreign Investment and National Security Act (FINSA). She advises companies in a range of industries, including the oil and gas, aviation, pharmaceutical, manufacturing, technology, chemical, and financial sectors.
Experience prior to joining Ropes & Gray:
- Counseled various U.S. and Russian companies on debt and equity financing and energy sector restrictions under OFAC’s Ukraine-related sectoral sanctions.
- 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.
- Advised financial institutions on methods for conducting customer KYC due diligence; screening customers against various restricted parties lists; resolving false positives; and filing reports with OFAC and FinCEN.
- Prepared voluntary disclosures related to potential violations of U.S. sanctions programs, including the hiring of sanctioned country 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.
- Counseled large U.S-based manufacturer of agricultural and chemical products regarding compliance with U.S. export controls, including the development of compliance policies and procedures regarding U.S. export controls, sanctions and anti-boycott regulations and obtaining export control licenses authorizing the export of controlled chemicals.
- 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.
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.
- Russian telecommunications company – due diligence review in connection with planned acquisition of telecommunications company.
- Advised major U.S. mining company regarding implications of proposed acquisition of certain of company's assets under FINSA and the Exon-Florio Amendment; prepared joint notice to CFIUS regarding proposed transaction; received clearance of transaction following 30-day review by CFIUS; advised client regarding the classification of its technology and products under applicable U.S. export control regulations.
- Represented large non-U.S. exploration company in connection with clearance by CFIUS of its acquisition of a U.S. navigation company; advised client on compliance with ITAR risks and responsibilities associated with the acquisition; assist client with implementation of CFIUS mitigation requirements.
- Advised major U.S. chemical company regarding the implications under Exon-Florio of the possible acquisition of a U.S.-based subsidiary of the client by a state-owned company based in the Middle East; assisted client in responding to requests for information received from the CFIUS.
- Represented oil refining company before CFIUS in connection with the purchase of a U.S. refining facility by Chinese-owned company; prepared Joint Voluntary Notice to CFIUS and represented client in CFIUS investigation; received CFIUS clearance of the transaction under Exon-Florio, as amended by FINSA; conducted review of client's government contracts and technology for purposes of CFIUS investigation and classification of export-sensitive items.
- 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)