George Grammas, partner in the Washington DC office, leads Squire Sanders’ International Trade and Export Controls Practice and the Aerospace and Defense Industry Group. He routinely advises on US laws and regulations governing international trade including exports and imports, economic sanctions, anticorruption, antimoney-laundering and antiboycott compliance; international technology transfer; non-US investment and participation in US defense and critical infrastructure industries; and US participation in NATO and foreign government programs. He assists organizations in obtaining US government approvals and clearances and in strengthening their international trade compliance through risk assessments, investigations, government disclosures, compliance programs and internal training.

George’s primary areas of regulatory expertise are export controls, International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR); economic sanctions (OFAC); Customs and Border Protection (CBP); the Foreign Corrupt Practices Act (FCPA); security clearances under the National Industrial Security Program Operating Manual (NISPOM); clearing non-US investment in the US defense and critical infrastructure industries through the Committee on Foreign Investment in the United States (CFIUS); and government contracts (FAR and DFAR). He also represents petitioners and respondents in antidumping and countervailing duty proceedings.

In more than 20 years of practice, George has served as an adviser to industry associations and the US government including as an industry adviser to the State Department’s Bureau of Political-Military Affairs through the Defense Trade Advisory Group; co-chair of the Joint Defense Trade Committee of Electronic Industries Alliance and the Aerospace Industries Association; chair of the export controls committee for CANEUS International, a micro/nano technology association; international trade counsel to the Electronic Industries Alliance; and legal adviser to the Society for International Affairs, the government/industry association on defense trade and export controls.

George is the author of numerous articles in legal and trade journals and is a frequent speaker at conferences and retreats. He was named part of the Legal Elite for 2009 by the readership of Washington SmartCEO.

Representative Experience

International Trade Compliance


• Conducting an international trade compliance risk assessment of a multinational company, followed by internal investigations in the areas of export controls, economic sanctions and FCPA compliance, and two voluntary disclosures to regulators.
• Serving as an export controls ombudsman for a large multinational company including resolving day-to-day licensing and compliance matters, drafting compliance procedures, and drafting and implementing the training program.
• Establishing procedures and obtaining (deemed export) approvals for non-US citizen employees, professors and students working in the lab of a major educational institution.
• Establishing international trade compliance policies and procedures, providing compliance official and empowered official training and compliance awareness training in export controls, economic sanctions and FCPA for numerous companies every year.


Export Controls


• Assisting a US-based automatic test equipment company in negotiating and drafting contracts and in obtaining US State Department approvals for the export of defense articles and defense services in support of NATO and Middle East aircraft maintenance programs and direct manning personnel for the F-15, AWACS and other military platforms.
• Assisting a US-based information security company in determining US, French and Chinese export and import requirements and restrictions for dual-use encryption technology and obtaining mass market treatment for the products from the US Commerce Department.
• Developing and implementing strategy for sales, manufacturing and distribution of defense articles and defense services through affiliated companies in the United States and EU under technical assistance agreements and distribution agreements approved by the US State Department.
• Obtaining a commodity jurisdiction determination that a component used in spacecraft applications is under Commerce Department dual-use export licensing jurisdiction.
• Assisting a commercial communications satellite company in obtaining authorization to engage in final assembly and testing operations in Russia of communication satellites as well as authorization to launch from Russia.
• Conducting internal investigations and voluntary disclosures of export compliance for numerous companies every year.


Economic Sanctions


• Determining the application of OFAC regulations to a non-US automaker.
• Submitting a voluntary disclosure to OFAC concerning repair of aircraft equipment for an SDN.
• Evaluating services that could be performed on or for oil platforms and ships operating in Iranian territorial waters.
• Evaluating the application of US economic sanctions to dry lease of aircraft for use in flights among Venezuela, Iran and Cuba, among other locations.
• Obtaining licenses for export of medical devices to US-sanctioned countries.
• Investigating possible violations of US economic sanctions and submitting voluntary disclosures to OFAC.


FCPA/Anticorruption


• Serving as independent FCPA counsel for joint venture owned 50/50 by a non-US government instrumentality and US company.
• Investigating possible FCPA violations in Russia and implementing compliance measures for a global telecom equipment manufacturer.
• Evaluating the application of FCPA to oil industry joint venture activities in Latin America.
• Drafting and implementing FCPA, antimoney-laundering, antiboycott and export controls compliance provisions in a Middle East agency agreement for a large defense contractor.
• Investigating red flags that arose under FCPA compliance program related to overseas sales representatives.
• Providing FCPA compliance training for a national airline.


Customs


• Establishing proper customs valuation and classification for large capital equipment imports though a series of ruling requests and protests.
• Developing strategy for minimizing tariff obligations and establishing proper valuation, classification, origin and marking requirements for global companies.
• Defending a US-based company’s foreign trade subzone status against challenges raised by a US supplier.
• Representing parties in antidumping proceedings including electrolytic manganese dioxide from China, polyvinyl alcohol from China, aspirin from Turkey, calendar slides from Japan and flexible magnets from China and Taiwan.
• Persuading Customs to change its position concerning the classifications of merchandise through an internal advice request, protesting entries based on disputed classification and submitting a prior disclosure as a protective measure.


Foreign Investment/Access to US Defense and Critical Infrastructure Industries


• Acting as special counsel to a large Germany-based defense contractor on CFIUS and Defense Security Service approvals for acquisition of a cleared US-based contractor and participation in US government programs.
• Acting as special counsel to an Italy-based high technology company in acquisitions in the United States, clearing CFIUS review and bringing acquired companies into compliance with US export control requirements.
• Clearing an acquisition of a US-based telecommunications company by a China-based government-owned enterprise.
• Clearing CFIUS reviews involving many other acquisitions in the defense, high technology, telecommunications, chemical, energy and transportation industries.


Recent Speaking Engagements 


• C5 Export Controls Conference, Paris, France, “Voluntary and Directed Disclosures,” December 2010.
• ITAR Boot Camp, American Conference Institute, “Avoiding Unauthorized Exports of Technical Data and Defense Services,” October 2010.
• ITAR Boot Camp, American Conference Institute, “License Exemptions under the ITAR,” October 2010.
• “ITAR Workshop – How to Cure the Virus,” UK A|D|S/EGAD 2010, Stratford-Upon-Avon, Warwickshire, UK, July 12-14, 2010.
• Defense Export Controls Conference, American Institute of Engineers, “Avoiding Unauthorized Exports of Technical Data and Defense Services,” November 2009.
• Coping With Export Controls in Mixed Commercial and Military Business: “Turning the ITAR on Its EAR,” Fairfax County Chamber of Commerce, International Business Exchange Council, October 2009.
• Complying with Export Controls on International Tech Transfer, American Conference Institute, “Export Compliance and Licensing: Stored and Transmitted Data,” September 2009.
• “ITAR Workshop – How to Cure the Virus,” UK Defense Manufacturers Association/EGAD 2009, Stratford-Upon-Avon, Warwickshire, UK, June 8-10, 2009.
• “ITAR and Government Policies and Approvals for International Collaboration,” CANEUS 2009, NASA Ames Research Center, Moffett Field, California,
  March 1-6, 2009.
• “ITAR Controls on Technology Transfers and Outsourcing,” GOCA/DOIA 2008, Coeur d’Alene, Idaho, Oct. 13-16, 2008.
• “ITAR Workshop – How to Cure the Virus,” UK Defense Manufacturers Association/EGAD 2008, Bracknell, Berkshire, UK (July 7-10, 2008) and
  Stratford-Upon-Avon, Warwickshire, UK, Nov. 19-20, 2008.
• “ITAR Issues,” NDIA Manufacturing Division Conference, Arlington, Virginia, Nov. 14, 2007.
• “Dual/Third Country Nationals,” sponsored by the Society for International Affairs, Washington DC, June 11, 2007.
• ”ITAR Workshops – How to Cure the Virus,” UK Defense Manufacturers Association/EGAD 2007, Warwickshire, UK, April 3-4, 2007.
• “Gateway to India 2006: Opening the Golden Door: Paving the Way for Business Success,” International Business Exchange Council (IBEC), International Trade Association of Northern Virginia (ITANV), Confederation of Indian Industry (CII), Department of Commerce and TiE-DC, McLean, Virginia., Dec. 4, 2006.
• “Strategies for Complying with the ITAR in the Context of Collaboration in Aerospace Applications,” CANEUS 2006: Conference on Micro and Nano Technologies for Aerospace Applications, Toulouse, France, Aug. 27-Sept. 1, 2006.
• “Export Compliance in the Context of International Marketing and Business Development,” Law Seminars International: A Comprehensive Tour of Key Legal Areas for Corporate Counsel, McLean, Virginia, June 19, 2006.
• “Employing Foreign Nationals: Laws, Threats, Practices,” INTELCON 2nd Annual National Intelligence Conference and Exposition, Bethesda, Maryland,  May 8, 2006.
• “Challenges and Opportunities When the Best Solutions Utilize Non-US Products,” International Business Exchange Council (IBEC), McLean, Virginia, Jan. 24, 2006. 
• Conference director and speaker at multiple conferences for the Society for International Affairs.