Megan Gajewski Barnhill counsels foreign and domestic clients on regulatory matters related to international business transactions. Specifically, Ms. Barnhill advises clients on regulatory issues related to international trade, including U.S. export controls, trade sanctions, anti-boycott, registration and reporting under the Foreign Agents Registration Act (FARA) and anti-corruption.
Ms. Barnhill regularly advises clients on issues related to U.S. export controls administered by the Department of State, Directorate of Defense Trade Controls, and the Department of Commerce, Bureau of Industry and Security. Ms. Barnhill has experience conducting due diligence reviews and compliance audits, drafting comprehensive compliance programs, drafting license and agreement applications, preparing commodity jurisdiction and classification requests, preparing voluntary disclosures, responding to government requests for information and administrative subpoenas, and assisting in day-to-day compliance with the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR) and with export controls on nuclear activities and materials administered by the Department of Energy and the Nuclear Regulatory Commission. Ms. Barnhill also assists clients with understanding, preparing for, and complying with regulatory changes, including changes in regulations as a result of the administration’s Export Control Reform effort.
In addition, Ms. Barnhill counsels clients on issues related to trade sanctions administered by the Department of the Treasury, Office of Foreign Assets Control (OFAC), including sanctions programs related to countries (e.g., Iran, Syria and Cuba) and against individuals and entities. Ms. Barnhill has assisted clients in preparing license applications and in responding to administrative subpoenas related to trade sanctions issues. She also advises clients on compliance with the anti-boycott provisions administered by the Department of Commerce and the Department of the Treasury, on compliance with the Foreign Corrupt Practices Act (FCPA) and on companies’ and individuals’ registration and reporting obligations under the FARA.