Sanjay José Mullick

Partner International Trade & National Security

Washington, D.C. +1 202 389 5111

Sanjay José Mullick

Overview

Sanjay Mullick advises companies, sponsors and investors on export controls and economic sanctions risk assessment in conjunction with investments, offerings, and mergers and acquisitions. He also conducts internal investigations, handles voluntary self-disclosures, and designs and implements trade controls compliance programs. Mr. Mullick assists companies with navigating the export control aspects of software deployment, including global encryption controls, cloud computing, and offshore outsourcing. In addition, he counsels companies and financial institutions on compliance with economic sanctions, including considerations for market entry and implementation of corporate policies and procedures.

Mr. Mullick has a broad range of experience providing counsel on export controls administered by the Department of Commerce Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR); the Department of State Directorate of Defense Trade Controls (DDTC) under the International Traffic in Arms Regulations (ITAR); and the Department of Energy’s rules on nuclear exports, as well as economic sanctions administered by the Department of the Treasury Office of Foreign Assets Control (OFAC). He also advises on tariffs and import duties and on compliance and enforcement matters concerning the Bureau of Customs and Border Protection (CBP) and foreign trade zones (FTZ).

Mr. Mullick has advised companies and governments in international arbitration and litigation, including dispute resolution proceedings under the investment provisions of the North American Free Trade Agreement (NAFTA) and bilateral investment treaties (BITs), administered under the rules of the International Center for the Settlement of Investment Disputes (ICSID) and the United Nations Committee on International Trade Law (UNCITRAL).

Mr. Mullick has represented U.S. companies and foreign governments in trade remedy proceedings, including antidumping and countervailing duty investigations and suspension agreements before the Department of Commerce, the International Trade Commission and the Court of International Trade.

Transactions

  • Advised U.S. private equity firm and space infrastructure company on export controls and economic sanctions in connection with its SPAC merger, including leading outreach with the Directorate of Defense Trade Controls (DDTC).
  • Advised U.S. private equity sponsors on the tariffs and import duties risk exposure of proposed acquisitions, and provided counsel on business model and sourcing strategies to mitigate supply chain and value chain impacts.

Counseling

  • Counseled Chinese automobile manufacturer on counterparty’s economic sanctions and export controls compliance allegations and negotiated settlement of related claims.
  • Counseled Chinese pharmaceutical company on U.S.-China regulatory risk, including business model strategic considerations and guidance on designing compliance program.
  • Designed for U.S. private equity firm national security trade controls risk assessment for its 25 portfolio companies and advised on remedial actions at the sponsor and company levels.
  • Performed for multinational oil and gas sector equipment and technology provider trade controls risk assessment and advised on contractual provisions with Chinese counterparties.

Investigations

  • Represented U.S. digital security provider in responding to Office of Foreign Assets Control (OFAC) Subpoena, including coordinating investigation and liaising with U.S. government.
  • Represented U.S. media company in voluntary self-disclosure to OFAC and the Bureau of Industry and Security (BIS), including devising export controls compliance program.
  • Advised U.S. automotive technology company under investigation by U.S. Customs and Border Protection (CBP), including implementing import compliance program.
  • Represented UK private equity firm’s U.S. flooring manufacturer portfolio company in penalty action before CBP, including conducting settlement negotiations with CBP officials.

United States Department of Commerce, Office of the Chief Counsel for Import Administration

Pillsbury Winthrop Shaw Pittman LLP

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Thought Leadership

Publications

“Latest Sanctions Narrow Path to Legal Dealings in Russia,” Law360 (October 7, 2022).

“Commerce Department Issues Proposed Rule Suspending Solar Tariffs,” Kirkland & Ellis LLP Energy & Infrastructure Blog (July 17, 2022).

“10 Takeaways From OFAC’s Settlement Agreements with Non-U.S. Banks,” New York Law Journal (September 28, 2021).

“Ten Takeaways From SAP’s Recent Export Controls and Economic Sanctions Settlement Agreements,” Reuters Legal (June 14, 2021).

“New Cybersecurity Executive Order Emphasizes Enhancing Software Supply Chain Security,” Westlaw Today (May 24, 2021).

“A Quick Look at New Regulations to Address National Security Threats in Shell Company and Digital Currency Transactions,” Anti-Corruption Report (April 28, 2021).

“Cyber Threats from North Korea and Risks and Recommendations,” The Review of Banking & Financial Services (March 26, 2021).

“Export Controls, Sanctions Policies Could Shift Under Biden Administration,” Bloomberg Law (February 19, 2021).

“EO Sets in Motion Ban on Transactions With Chinese App Developers and Owners,” Corporate Compliance Insights (January 5, 2021).

Seminars

“OFAC Enforcement Actions: Recent Trends and Lessons for Industry,” Celesq (December 13, 2021).

“A Discussion on Carbon Tariffs and Trade,” Energy Bar Association Mid-Year Energy Forum (October 12, 2021).

“The USMCA’s Impact on the North American Energy Industry,” National Association of Regulatory Utility Commissioners Committee on International Relations Summer Policy Summit (July 14, 2021).

“Export Controls & Supply Chain: Staying Compliant with Increased Global Export Controls Regulations and National Security Rules,” American Conference Institute’s Asia Pacific Advanced Conference on Economic Sanctions Compliance Enforcement (May 28, 2021).

“U.S. Export Controls: Recent Developments, Key Takeaways, and Anticipated Changes Ahead,” Strafford Legal (November 11, 2020).

“The New NAFTA: The Good, Bad and Ugly,” Energy Bar Association - Canadian Chapter (September 24, 2020).

“U.S. Sanctions: Regulatory Developments,” Strafford Legal (May 13, 2020).

“Intersection of Cybersecurity and GDPR,” American Conference Institute Global Encryption, Cloud & Cyber Trade Controls (March, 26, 2019).

“OFAC Guidance on North Korea: Clarification to Minimizing Risks in Your Supply Chain,” American Conference Institute New York Forum on Economic Sanctions (December 7, 2018).

“International Trade Challenges and Strategies,” China General Chamber of Commerce (October 15, 2018).

Media Mentions

“USMCA Could Solve Supply Chain Problems,” International Financial Law Review (November 3, 2021).

“Automobile Industry’s Country of Origin Dispute Acting as USMCA Road Test,” International Financial Law Review (September 28, 2021).

“Biden and Erdogan Meet as U.S. Sanctions Hang Over Turkey Following Russian Missile Deal,” CNBC (June 14, 2021).

“Biden to Face Trade Test Over Energy Market Access in Mexico,” National Journal (December 10, 2020).

“Trump’s Security Order Could Have ‘Chilling Effect,’ Slow Smart Grid Deployment, Experts Say,” Utility Dive (May 7, 2020).

“U.S. Tightens Export Restrictions to Keep Tech Out of Chinese Military’s Hands,” South China Morning Post (April 29, 2020).

“Aggressive U.S. Energy Policy Tests Ties With European Allies,” The New York Times (July 10, 2019).

“Capture of ‘Sanctions Busting’ Ship Puts Spotlight on U.S. Banks,” Global Investigations Review (May 10, 2019).

“Uncertain Future of NAFTA Revamp Has Some Companies ‘Waiting and Hoping’,” Corporate Counsel (April 4, 2019).

“Tough Sanctions on Venezuela’s Crude Extend Past U.S. Borders,” Daily Business Review (February 7, 2019).

“U.S. Export Controls Leave Compliance Officers Guessing,” ACAMS moneylaundering.com (August 14, 2018).

“U.S. Move May Trigger Iran ‘Exit’ for Foreign Subsidiaries,” The Wall Street Journal (June 28, 2018).

“The Morning Risk Report: Companies Walk Away From Iran,” The Wall Street Journal (May 21, 2018).

“FinCEN AML Compliance: Between a Rock and a Hard Place,” Commercial Dispute Resolution (March 21, 2018).

“The Morning Risk Report: U.S. to Target Russian Oligarchs,” The Wall Street Journal (March 16, 2018).

Recognition

Law360's 2021 International Trade Editorial Advisory Board

The National Law Journal, “Crisis Leadership Trailblazer”

Legal 500 US, International Trade

Recipient of The John Carroll Society Pro Bono Legal Award

Memberships & Affiliations

District of Columbia Bar, International Law Committee

Georgetown University Alumni Admissions Program

Georgetown University Athletics Women’s Allegiance

Credentials

Admissions & Qualifications

  • District of Columbia

Courts

  • United States Court of International Trade
  • United States Court of Appeals for the Federal Circuit
  • District of Columbia Court of Appeals

Languages

  • Spanish

Education

  • Georgetown University Law CenterJ.D.1996

    Foreign Publications Editor, Georgetown International Environmental Law Review

  • Georgetown University Walsh School of Foreign ServiceB.S., International Politics1991