Daniel E. Waltz

Dan focuses on the policies and regulations imposed by the US that seek to sanction or embargo foreign countries, such as Cuba, Iran, Russia and Venezuela. He assists clients in obtaining licenses, counsels them with respect to changing US policy and represents them in enforcement proceedings. He has also worked to change US policies with respect to certain embargoes, sometimes incrementally in connection with a single license application, and sometimes more broadly, as with the US embargo of Cuba.

With respect to imports, Dan assists clients on matters relating to the full range of Customs issues, whether it be valuation, classification, country of origin labeling or the availability of a particular tariff preference program (GSP, CBI, AGOA, etc.). He prepares and files protests, requests for internal advice, letter ruling requests and represents clients in administrative penalty matters. When necessary, he litigates on behalf of his clients before the Court of International Trade and the Court of Appeals for the Federal Circuit. He also assists importers with respect to requirements imposed by agencies other than Customs, including the US Department of Agriculture (USDA), Food and Drug Administration (FDA), Federal Trade Commission (FTC) and Consumer Products Safety Commission.

With respect to exports, Dan assists clients, both domestic and foreign, in understanding and complying with US export controls. These include State Department regulations that govern the international transfer of defense articles, defense services or technical data, and Department of Commerce regulations that govern "dual-use" products and technology. Dan obtains rulings, to help clients apply for and obtain licenses, and represents clients in administrative compliance and enforcement actions.

For the last 10 years, Dan has also been responsible for the firm’s compliance with the Foreign Agents Registration Act (FARA). The firm has more active FARA registrations at any one time than any other firm in the country. Dan is responsible for assuring that the firm’s short-form registrants are aware of and comply with FARA’s disclosure requirements and oversees the preparation and submission of the firm’s bi-annual Supplemental Statements that disclose the firm’s FARA-registrable activity for each six-month reporting period. Given his FARA-related expertise, Dan also advises clients on their FARA-related obligations. In recent years, the Department of Justice’s FARA Unit has ratcheted up its enforcement of FARA. Thus, both on behalf of the firm and on behalf of firm clients, Dan has drafted and submitted responses to letters sent by the FARA Unit asking why a particular client or a particular representation is not required to register under FARA.

Dan also advises clients on the Buy American program and the various Buy America programs administered by different offices within the US Department of Transportation.

With respect to corporate transactions, Dan routinely advises clients on issues arising under the Foreign Corrupt Practices Act (FCPA). He assists clients in conducting due diligence and identifying and mitigating risks. He also assists clients in developing or upgrading FCPA compliance programs and frequently offers FCPA training.

On broader trade policy issues, Dan has represented foreign governments in GSP proceedings, fought to defeat the imposition of new export controls and lobbied on various trade-related bills before the Congress. He also assists clients in the structuring, negotiation and drafting of international sales, distribution and agency agreements, assists clients in the resolution of disputes arising from international trade transactions and advises on issues relating to US anti-boycott regulations.