A counsel in the Litigation Department, Josh focuses his areas of practice on international trade, national security, and anti-corruption topics across a variety of matters, including regulatory counseling, internal investigations, investment reviews, and transactional due diligence. Josh advises clients on a range of international trade laws and regulations, including: sanctions administered by the Department of the Treasury’s Office of Foreign Assets Control (OFAC), export controls administered by the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of State’s Directorate of Defense Trade Controls (DDTC), and investment reviews before the Committee on Foreign Investment in the United States (CFIUS).
Experience
Josh’s recent representations include:
- a multinational retailer in a U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) disclosure and related investigation involving the resale of merchandise to Iran;
- a Chinese multinational technology and entertainment company in connection with ongoing sanctions, export control and anti-money laundering advice;
- a major sports association in submitting license applications with the U.S. Department of Treasury’s Office of Foreign Assets Controls seeking OFAC approval to interact with certain sanctioned persons and jurisdictions that may participate in related events or interact with the company’s legal and compliance team;
- a manufacturing and biotechnology company regarding national security issues, including engaging with CFIUS;
- a major technology company in a risk assessment of the money laundering enforcement risk related to certain of its products;
- an aerospace manufacturing company in relation to a cybersecurity incident in which malware affected several business units and company data was exposed. The response included overseeing remediation for affected systems, corresponding with applicable government authorities and developing a communications strategy;
- a non-U.S. steel manufacturer in connection with its acquisition of a U.S. company;
- a major U.S. private equity firm on a variety of CFIUS and U.S. national security issues related to onshore and offshore investments and acquisition structures; and
- a U.S.-based global alternative investment manager, in obtaining CFIUS approval of a minority stake in its business to an Asian company.
Josh regularly writes on sanctions, anti-money laundering and national security matters. He authored the “USA” chapter of the International Comparative Legal Guide – Sanctions (Global Legal Group Ltd.) from 2021–2024 and served as a contributing editor for the publication from 2022–2024. During that time, he also authored the expert analysis chapter, “Recent Developments in U.S. Sanctions: Russia Sanctions, OFAC Enforcement Trends, and Compliance Lessons Learned.” He also co-authored the Law360 article “How Defense Bill Will Overhaul AML Policy In US” (2021), which examined anti-money laundering reforms included in the National Defense Authorization Act (NDAA).
