Co-chair of the International Trade Compliance Practice Group, Tahlia is trusted by Fortune 50 multinationals, leading universities, international law firms, emerging companies, and small businesses to provide prompt, practical, effective guidance and thought leadership on trade sanctions administered by the Office of Foreign Assets Controls (OFAC) and on U.S. export controls under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), and to develop tailored, risk-based programs for compliance with, obtain licenses for international activities regulated under, and conduct directed and voluntary investigations into potential violations of these trade control regulations.
Lauded by her clients for responsiveness, practicality, and a level of care and service that is "terrifyingly good," and valued for the additional skills she brings to bear from her training in physics, chemistry, computer science, and litigation, Tahlia has assisted clients in sectors such as aerospace, banking, defense, insurance, logistics, venture capital, legal services, electronics, optics, communications, and education with a wide variety of trade compliance issues, large and small. A sample of those matters includes
- Developed and drove implementation of a global program for OFAC compliance for a Fortune 200 company with operations all over the world.
- Conducted hundreds of investigations into potential violations of U.S. trade sanctions and export controls and prepared scores of thorough and clearly written disclosures to the Office of Defense Trade Controls Compliance (DTCC), the Office of Export Enforcement (OEE), and OFAC, almost all of which were resolved without penalties.
- Advised on the use of OFAC general licenses or prepared applications for specific licenses to authorize a wide range of exports and re-exports, including of oil-industry-related engineering services, medical devices, food additives, contact lenses, legal services, and activities conducted by U.S.-owned foreign companies under General License H.
- Advised on and developed procedures for complying with General License H, OFAC's "facilitation" prohibition as applied to U.S. ex-patriot board members; legal representation of Specially Designated Nationals (SDNs); reinsurance of projects involving Cuba Restricted List entities; and payment of fees by foreign students from, hiring of foreign academics from, and attending conferences or collaborating on research with universities and academics in embargoed regions.
- Prepared self-classification memoranda, Commodity Jurisdiction (CJ) requests, and Commodity Classification Automated Tracking System (CCATS) requests for a wide range of products, including infrared lenses, laser-driven light sources, data cables, unmanned aerial vehicles, aircraft components, metal alloys used in aerospace applications, and fabric used in the manufacture of aerostats, and prepared applications for ITAR Technical Assistance Agreements (TAA), Manufacturing License Agreements (MLA), ITAR temporary and permanent export licenses, and BIS export licenses for a wide range of products and programs.
