Ama Adams is managing partner of the Washington, D.C. office and a partner in the firm's Litigation and Enforcement practice. She has over 20 years of experience advising clients 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.
Experience
International Trade Enforcement and Compliance Matters
- Represented U.S. private equity firm and its portfolio company, a software and automation solutions company, in responding to OFAC subpoena concerning potential diversion concerns
- Represented life sciences company in disclosure to the U.S. Department of Justice concerning potential misconduct involving sanctioned jurisdictions
- Represented ship management company in navigating disclosure and licensing issues concerning SDN designation of counterparty
- Represented non-U.S. financial institution in voluntary disclosure and favorable settlement negotiations with OFAC concerning potential violations of sanctions
- Represented international life sciences company in reinstating Customs Trade Partnership Against Terrorism (CTPAT) status
- 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 global private equity firm with an internal investigation involving a technology product and services portfolio company for potential violations of the Iran sanctions regulations
- 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.
- 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.
- 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.
- Conducted a global risk assessment of the supply chain and trade compliance program of multinational off-price department store corporation, including a review of restricted party screening protocols, licensing processes and anti-boycott procedures.
- Lead trade compliance counsel for several leading private equity firms, which involves, inter alia, conducting extensive international risk assessment of sanctions, export control, antiboycott and FCPA compliance practices of contemplated target companies with global operations, advising on contractual remedies and mitigation strategies, and implementing sanctions compliance programs and uplifts for incoming portfolio companies
CFIUS – Reviews, Investigations, and Compliance
- Represented a Hong Kong-based technology company in securing CFIUS clearance in connection with its acquisition of a U.S.-based semiconductor advanced packaging business.
- Represented a German-headquartered copper manufacturer in obtaining CFIUS approval in regards to its acquisition of a leading, value-added converter, fabricator, processor and distributor of specialized non-ferrous products in North America.
- Represented a U.S. health care software company in obtaining CFIUS clearance for investment by Asia-based investor
- Represented a U.S. health care management company in obtaining CFIUS pre-clearance in connection with the acquisition of board rights by a European investor
- Represented European asset management firm in obtaining CFIUS clearance in connection with the transfer of a sensitive infrastructure asset located on a U.S. military base to a Canadian investor
- Represented a U.S. infrastructure platform backed by European and Middle Eastern institutional investors in successful CFIUS filings in connection with the acquisition of infrastructure assets
- Represented a U.S.-based manufacturing company in navigating non-notified CFIUS inquiry and filing concerning investment by Asia-based investor
- 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.
- Assisted leading life sciences company develop and implement a customized CFIUS playbook of policies and procedures
- Assist multiple private equity firms, venture capital firms, and sovereign wealth funds conduct CFIUS assessments of hundreds of investment targets per year