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This Month in International Trade - September 2013

Sep.30.2013

THIS MONTH'S TOP TRADE DEVELOPMENTS

1) Trading Deadline?: The Looming Government Shutdown

Barring a last second deal on Capitol Hill, the Federal Government will shut down at 12:01 AM on October 1st. All non-essential federal workers will be furloughed and many agency operations will cease. How will it impact trade?

Without funding, agencies cannot continue routine operations and administrative activities. Agencies cannot incur new financial obligations without a current appropriation. However, not all activity will stop. Agencies can continue to provide emergency services and services funded outside the appropriation process.

The practical impact will therefore vary dramatically. For importers, Customs and Border Protection (CBP), will retain up to 90 percent of its existing employees, while for exporters, the Commerce Department's Bureau of Industry and Security (BIS), will retain only 40 percent of its personnel. Below is a more detailed description of the shutdown plans for many federal agencies:

Customs and Border Protection (CBP)

  • Continue passenger processing and cargo inspection functions at ports of entry.
  • Continue CBP revenue collections.
  • Continue to secure the Nation's borders, maintaining criminal law enforcement operations including drug and illegal alien interdiction.
  • Continue counter-terrorism watches or intelligence gathering or dissemination in support of terrorist threat warnings.
  • Planning, research and development, and training activities will be curtailed.
  • Most policy functions, administrative, as well as programmatic, unless those functions can be justified by an exception (necessary for safety of human life or protection of property, etc.), will be curtailed.
  • Auditing and regulatory, legislative, and public affairs will be curtailed.

Bureau of Industry and Security (BIS)

  • Office of Export Enforcement (OEE) special agents will continue investigations, prosecutions, and other activities with DOD, DOJ, FBI, ICE, and other law enforcement and intelligence agencies.
  • Continue to processing export licenses essential to protecting the national security of the United States.
  • Continue to evaluate transactions involving U.S. controlled items to ensure they are exported in accordance with export control requirements.
  • Continue to draft amendments to the Export Administration Regulations to address emergency foreign policy issues that warrant changes to dual-use export control policies.
  • Continue to negotiate changes to international export control lists.
  • Continue to host international inspectors pursuant to U.S. non-proliferation treaty obligations.
  • Continue to process emergency priorities and allocation requests to ensure national security programs have access to necessary items.

Office of Foreign Assets Control (OFAC)

  • Continue to monitor and update the list of Specially Designated Nationals.
  • Continue to implement and administer new sanctions on foreign countries through new Executive Orders.
  • Limited hotline support for incoming inquiries.

Consumer Products Safety Commission (CPSC)

  • Continue to coordinate with CBP to monitor and conduct activities related to the importation of products that create a substantial and immediate threat to human safety.

Food and Drug Administration (FDA)

  • Continue to review imports offered for entry into the U.S. but will cease monitoring of imports.

Animal and Plant Health Inspection Service (APHIS)

  • Continue surveillance activities prevent the introduction of animal and plant pests into this country that would be potentially damaging to American horticulture and livestock.

Department of Justice

  • All criminal litigation will continue.
  • Civil litigation will be curtailed or postponed to the extent possible without compromising human life or property.
  • If a Court orders a case to continue, DOJ will continue to pursue it.

Department of Commerce

  • Continue export enforcement – criminal investigations, prosecutions and coordination with law enforcement and intelligence agencies.
  • Most services and activities provided by the International Trade Administration will not be available.
  • Certain matters essential to World Trade Organization litigation will be available.

For more information on how the shutdown could affect your business, or how to best negotiate its impacts if it occurs, contact: John Brew, Dan Cannistra, Michael Larmoyeux, Dj Wolff

2) U.S. Trade Policy in Overdrive

The U.S. trade negotiations agenda has taken an intense turn in recent weeks, with the fall and winter months likely to be characterized by a frantic pace of activity on multiple fronts. Companies have an increasing array of venues and opportunities for advancing their commercial objectives through government-to-government trade negotiations. By the same token, the accelerating pace and overlapping nature of these negotiations will create particular challenges in terms of staying on top of fast-breaking developments and ensuring that opportunities are seized.

The U.S. trade agenda is currently dominated by a major push to conclude negotiations for a Trans-Pacific Partnership (TPP) free trade agreement. The TPP, which aims to knit together 12 North American and Asia Pacific economies, has been advancing at a near-glacial pace for the past three years. Since late summer, however, U.S. Trade Representative Michael Froman and his TPP counterparts have been pressing their respective negotiators to resolve outstanding issues in the hopes of teeing up breakthroughs that can be announced by trade ministers at the annual Asia Pacific Economic Cooperation (APEC) forum meeting in November. As of late September, senior negotiators were meeting virtually non-stop to hash out outstanding differences on issues such as intellectual property rights, disciplines governing state-owned enterprises, and a host of complex legal issues, along with tackling highly sensitive market access issues for agricultural products, textiles and clothing. While prospects for fully concluding the TPP before the end of 2013 remain questionable, the political impetus to close a deal has become intense. Indeed, some U.S. industry groups have expressed concern that the new emphasis on speed should not result in a reduction of ambition for the agreement's market access and rules-based outcomes.

Meanwhile, U.S. negotiators are gearing up for a second round of discussions with the European Union as part of negotiations for a Transatlantic Trade and Investment Partnership (TTIP). These meetings, scheduled for the second week of October, are likely to build on earlier discussions aimed at defining the scope, organizational structure, and respective priorities for this extremely ambitious and complex trade negotiation. The period between October and the anticipated next round of negotiations in December will be critical for U.S. companies, as negotiators in Washington and Brussels begin outlining textual proposals that will be the foundation of the negotiation process going forward. 

As these two major regional free trade negotiations move ahead, U.S. trade negotiators are simultaneously moving ahead with plurilateral negotiations for a new international Trade in Services Agreement (TISA). The United States in recent days offered a proposal to open additional services sectors to foreign participation through the TISA, recognizing longstanding U.S. limitations to foreign access in the maritime and air transportation sectors. And while Geneva-based negotiations to expand duty-free treatment for information technology products are currently on hold as a result of China's perceived lack of ambition, those talks may also revive at some point in the coming months.

The concurrence of these major trade policy initiatives is placing considerable pressure on negotiators at the Office of the U.S. Trade Representative, an agency that was already struggling with significant budget and human resource constraints. The competing demands on the attention of U.S. negotiators further reinforces the importance of targeted, focused, and well-prepared engagement on the part of private sector stakeholders with an interest in these processes.

Finally, on the legislative front, it remains possible that the Congress will, later this year, begin consideration of renewing Trade Promotion Authority, which authorizes the President to negotiate trade agreements on the basis of specific objectives (authority which will be necessary to enable Congressional consideration of eventual final TPP and TTIP agreements). In addition, Congress may be considering renewal of the Generalized System of Preferences (GSP), a program providing duty-free import treatment for products originating from developing countries; GSP formally expired at the end of June and reactivation of the program requires new legislation.

Crowell & Moring and its trade policy consulting affiliate C&M International are actively engaged in all elements of this intensifying swirl of trade policy activity. We would welcome the opportunity to assist companies with strategy development and advice on engaging with negotiators.

For more information, contact: Jonathan ("Josh") Kallmer, Christopher Wilson

3) EU and U.S. Continue to Diverge on Iranian Sanctions

On September 16th, the EU General Court threw out sanctions imposed by the Council of the European Union against an entity whose assets had been frozen due to association with Iran's nuclear program. The action to sanction the Tehran-based Islamic Republic of Iran Shipping Lines (IRISL) was annulled after the Court found the EU Council did not do enough to back its conclusion that IRISL had a connection to nuclear proliferation in Iran.

The EU General Court has used this same rationale to remove sanctions from six other Iranian-linked entities already this year: Post Bank Iran, Iran Insurance Co., Good Luck Shipping & Export, the Export Development Bank of Iran, Bank Saderat Iran, and Iran's Bank Mellat.

This growing divergence in designations threatens the consolidated front that the United States and the EU have developed in the last several years with respect to Iranian sanctions.  More practically, more U.S. companies it raises challenges for multinational companies who now face variable regimes in the EU and the U.S., where are all six entities remain on the Department of the Treasury's Specially Designated Nationals (SDN) list.

This trend further highlights the need for multinational countries to constantly monitor the ever-changing landscape of embargoes and economic sanctions in each of the jurisdictions to which they might be subject.

The September 16th EU General Court Ruling may be found here.

For more information, contact: Cari Stinebower, Dj Wolff, Edward Goetz

4) Three More Antiboycott Settlements Against U.S. Companies

In September, the U.S. Department of Commerce's Office of Antiboycott Compliance (OAC) issued two more settlements of alleged violations of OAC's antiboycott regulations. In keeping with recent trends, these per violations penalties are moderately higher than their historical averages:

  • Laptop Plaza Inc. - OAC announced a settlement of $48,400 against Laptop Plaza Inc., a U.S. company organized in Delaware. OAC alleged that on 4 occasions in 2006, Laptop Plaza furnished prohibited boycott related information in transactions involving Lebanon and Pakistan. Additionally, OAC alleged that Laptop Plaza failed to retain records from three other transactions in 2006 despite having been issued a subpoena within the statute of limitations.
  • Leprino Foods Company - Second, OAC announced a settlement for $32,000 against Leprino Foods Company, a Colorado-based exporter of cheese and dairy products. Specifically, OAC indicated that on 1 occasion in 2011, Leprino Foods furnished prohibited information in a transaction involving Oman, while on 15 separate occasions in 2010 and 2011, Leprino Foods failed to report the receipt of boycott-related requests from Oman and Bahrain.
  • Digi-Key Corporation - Finally, OAC announced a $56,600 penalty against Digi-Key, a Minnesota electronic parts distributor. The settlement alleges that on 5 occasions between 2008 and 2011 - including several violations which transpired by email - Digi-Key furnished prohibited boycott-related information in connection with transactions to the UAE and Malaysia, while on 58 occasions during the same time period, Digi-Key received boycott-related requests from the same countries that it failed to report.

These settlements offer several lessons for U.S. companies. First, OAC is increasingly willing to issue larger fines to punish allegedly prohibited behavior. Despite announcing roughly half as many settlements thus far in 2013 as in 2012 (5 to 9), the total penalty amount has been more than three times higher ($371,705 v. $129,000). Second, OAC's penalty to Digi-Key offers a reminder that information furnished by email is also subject to the antiboycott regulations and can get exporters into trouble.

Finally, for the first time OAC has imposed a penalty for a recordkeeping violation. In the Laptop Plaza case, the five year required record retention period had expired. However, before the period expired, OAC had issued Laptop Plaza a subpoena which included these documents. Laptop Plaza's subsequent destruction of the documents in accordance with its normal record retention policy was thus a violation of the subpoena. The case thus serves as a warning to exporters to maintain vigilant compliance with both OAC's recordkeeping requirements and all OAC subpoenas.

For more information, contact: Jeff Snyder, Dj Wolff

5) CBP Test Program on Manifesting, Entering Certain Residual Cargo

Effective on November 25, 2013, CBP will begin a pilot test of phasing in ruling HQ H026715 (June 19, 2009). This ruling states that importers should not manifest as empty any containers arriving as Instruments of International Trade (IIT) and having residual cargo. Instead, residue within these containers must be classified, entered and manifested. CBP has decided to launch a one-year, nationwide test program to enforce this ruling. This program will allow for a new residue entry that can be made off the manifest and is designed to account for residue in containers that will be cleaned or refilled. 

According to the Federal Register notice regarding the new test program, any party not participating in this test will be required to classify, enter and manifest (through formal or informal entry) residual cargo according to the relevant statutes and their implementing regulations. The test will use existing functionality so no programming changes will be needed. There will also be no application process, which enables interested parties to begin participating in the test whenever they choose. Furthermore, there will be no additional bonding requirements for the test, and Air Cargo Advance Screening filings will not be required for containers with residue in the air environment. 

Under the program, any container arriving clean (i.e., with no residue) must be manifested as an empty IIT but entry will not be required. Arriving containers that contain cargo in excess of a specified percentage of the total capacity of the container by weight or volume, using industry standards, must also be manifested. These percentages are:

  • 7 percent for rail shipments
  • 5 percent for air shipments;
  • 3 percent for truck and vessel shipments.

A consumption entry will be required for each container, either formal or informal, depending on its value and applicable regulations. Entry requirements and duty payments as well as taxes and fees will continue to remain applicable as provided by law. See Federal Register on August 27, 2013, 78 FR 52958.

Any arriving container with a total cargo capacity exceeding one of the above percentages by weight or volume, using industry standards, will be considered as containing residual cargo. The container must therefore be manifested and entered as having residue. If the residual cargo has no commercial value (i.e., the container will either be cleaned with the residue destroyed or refilled for export), CBP will:

  • accept the declaration of the carrier, or the importer of record, that the residue has no commercial value and that the country of origin is the country from which the container is arriving;
  • require that the type of residue be classified up to the six-digit HTSUS number;
  • require a residue entry designating that the residue cargo has no commercial value. 

CBP will release this merchandise under the low value mechanism of 19 U.S.C. 1321. This mechanism is when the carrier can waive the right to make a residue entry and the entry can be made off the manifest with no further documentary requirements if the container is below the set limits. Therefore, no merchandise processing fee or harbor maintenance fee will be due. Additionally, a manifest record indicating that a residue entry has been filed will be sufficient to meet recordkeeping requirements, which must be maintained by the entry filer.

For more information, contact: John Brew, Michael Larmoyeux, Carolyn Esko

THIS MONTH IN TRADE – OTHER NEWS

Agency Enforcement Actions

Bureau of Industry and Security (BIS)

Office of Foreign Assets Control (OFAC)

  • Turkish Company Assessed $750,000 Penalty for Violations of Iran Sanctions. Finans Kiymetli Madenler Turizm Otomotiv Gida Tekstil San, a trading company based in Turkey, allegedly originated electronic transfers through the U.S. for the benefit of the Government of Iran and/or persons in Iran. OFAC determined that Finans acted recklessly by concealing material information while processing these fund transfers, that these transfers resulted in harm to U.S. sanctions program objectives, and that Finans failed to cooperate with OFAC during its investigation. Finans was assessed a penalty of $750,000.
  • California Company Settles for $340,000 for Violations of Iran Sanctions. Communications and Power Industries LLC (CPI), a company based in Palo Alto, California, allegedly sold x-ray generators and a medical digital imaging workstation to an entity in Iran. CPI voluntarily disclosed these violations, and OFAC found that the violations were not egregious. CPI settled with OFAC for $346,530.
  • Florida Company Settles for $39,000 for Violations of Cuba, Iran and Sudan Sanctions. World Fuel Services Corporation, a company based in Miami, Florida, allegedly facilitated through its subsidiary the sale of fuel for vessels at Bandar Abbas, Iran, and Khartoum, Sudan, and also coordinated through its subsidiaries unlicensed flights to Cuba. World Fuel voluntarily disclosed these violations, and OFAC found that the violations were not egregious. World Fuel settled with OFAC for $39,501.
  • VISA International Service Association Settles for $2,900,000 for Multiple Sanctions Violations. Intesa Sanpaolo S.p.A., a bank headquartered in Italy, allegedly processed payments for Irasco S.r.L., a party owned or controlled by Iran, and processed wire transactions to or through the United States that involved Cuba or Iran. Intesa Sanpaolo did not voluntarily disclose these violations, but OFAC found that the violations were not egregious. Intesa Sanpaolo settled with OFAC for $2,949,030.

State Department

  • Aeroflex Settles for $8 million for ITAR Violations. Aeroflex Incorporated, a global provider of microelectronics to the aerospace, defense, cellular and broadband communications sectors, allegedly engaged in the unauthorized export of defense articles to China. Aeroflex settled with the State Department for $8 million.
  • Meggitt-USA Settles for $25 million for ITAR Violations. Meggitt-USA, Inc, an engineering company that specializes in components used in extreme environments, allegedly engaged in the unauthorized provision of defense services and the export of defense articles to various countries. Meggitt settled with the State Department for $25 million.

For more information, contact: Richard Massony, Dj Wolff

Export Control Reform Update

On August 30, 2013, the Department of State issued an industry notice stating that effective September 1, the Directorate of Defense Trade Controls (DDTC) will review newly submitted commodity jurisdiction (CJ) requests that involve articles or services relating to U.S. Munitions List Category VIII (Aircraft and Related Articles) and Category XIX (Gas Turbine Engines and Associated Equipment) pursuant to the rule revising these categories (Amendment to the International Traffic in Arms Regulations: Initial Implementation of Export Control Reform, Federal Register, Vol. 78, No. 73, April 16, 2013).

This change is necessitated due to current processing times for CJs (approximately 60 days), as the final determinations for CJs submitted after September 1 will not be issued until after the effective date (October 15, 2013) for the above referenced rule. DDTC noted this change does not affect those requests that have already been submitted and are under review.

DDTC advises exporters and manufacturers to continue using the current control criteria on the U.S. Munitions List until the new control criteria take effect on October 15, 2013. Department of State will implement similar policies for CJ requests for other USML Categories under revision pursuant to Export Control Reform 60 days prior to their effective dates.

The notice may be found here.

For more information, contact: Jana del-Cerro, Chris Monahan, Edward Goetz

Reopening of Korean Neutral Zone Poses North Korea Sanctions Risk

Reports indicate that operations have resumed at North Korea's Kaesong Industrial Complex, the neutral zone of economic cooperation between North and South Korea. Products of Kaesong are treated as originating in North Korea for purposes of U.S. sanctions law: they cannot be imported into the U.S. without prior authorization from the Office of Foreign Assets Control (OFAC). Other reports indicate that goods from Kaesong are often sold into international supply chains through neighboring countries, including Korea and China. Therefore, companies sourcing goods from Korea or China should screen suppliers to ensure that they are not receiving North Korean-origin goods.

To continue reading this prior client alert, please click here.

For more information, contact: Jeff Snyder, Cari Stinebower, Richard Massony, J.J. Saulino

Amendment to the International Traffic in Arms Regulations (ITAR): Registration and Licensing of Brokers; Brokering Activities; and Related Provisions

On August 26, 2013, the Department of State issued an interim final rule amending the International Traffic in Arms Regulations (ITAR) relating to brokers and brokering activities. These amendments clarify registration requirements, the scope of brokering activities, prior approval requirements and exemptions, procedures for obtaining prior approval and guidance, and reporting and recordkeeping of such activities.

This rule is effective October 25, 2013; however, parties may submit comments on this rule by October 10, 2013. The Department will publish a final rule notifying of any changes to the rule pursuant to public comment assessment. The interim final rule may be found here.

For more information, contact: Jana del-Cerro, Chris Monahan, Edward Goetz

CBP East Coast Trade Symposium

U.S. Customs and Border Protection (CBP) will hold the 2013 East Coast Trade Symposium, "Increasing Economic Competitiveness through Global Partnership and Innovation" at the Washington Hilton Hotel in Washington, D.C. on October 24-25. The conference will feature panel discussions covering a variety of topics such as ACE Single Window, U.S. Exports, Air Cargo Advance Screening (ACAS), CEE Entry Lifecycle Management, Trusted Traders, and Partnership In Trade Enforcement. Register for the onsite event through the CBP website here (registration limited to a maximum of three participants per company).

For more information, contact: John Brew, Jini Koh, Michael Larmoyeux

U.S. Expropriates N.Y. Skyscraper Linked to Iran

After a lengthy legal battle, on September 16, a U.S. district court rules that the United States had established that 650 5th Avenue was owned by entities acting as fronts for Iran and could therefore be seized and used to settle outstanding U.S. judgments against Iran. Specifically, the Court found that the Alavi Foundation, the majority owner of the 650 skyscraper, provided services to the two minority owners who were acting as fronts for Iran's Bank Melli. This knowledge, explained in an 82-page opinion, constituted a deliberate effort to help Iran, which violates the International Emergency Economic Powers Act and U.S. money laundering laws. Judge Forrest wrote, "there is a far broader violation - one that involves not simply an unknowing and innocent provision of services to Iran, but providing those services to assist Iran by shielding and concealing Iranian assets."

In her opinion, Forrest contended Alavi provided services to the minority owners, Assa Corp and Assa Co Ltd, which "was (and is) a front for Bank Melli, and thus a front for the Government of Iran." 

While the Alavi Foundation only transferred money to Assa Corp domestically, the latter entity then transferred funds to Assa Col Ltd in the United Kingdom. The Court held that this multi-step plan to transfer money out of the United States "should be viewed as a single transaction," regardless that the first step of the transfer was wholly domestic. Alavi did not dispute that it knew the second transaction took place.

The ruling establishes a strong precedent for the ability of parties to connect Iranian-linked assets to the Government of Iran and to potentially attach them to satisfy pending judgments. Considering the amount of money at stake as well as the court's skepticism of a potential "innocent owner" defense, this threshold may lead parties to initiate further actions against assets subject to U.S. jurisdiction with an even more tangential relation to Iran.

The ruling (U.S. District Court, Southern District of New York, No. 08-10934) can be found here

For more information, contact: Cari Stinebower, Dj Wolff, Edward Goetz

First TIFA Investment Working Group Meeting between U.S., Taiwan

On September 12, U.S. and Taiwanese officials held the first meeting of the Trade and Investment Framework Agreement (TIFA) investment working group, formed during TIFA meetings in March. Participation in the working group took place between representatives of the American Institute in Taiwan (AIT) for the U.S. side; and the Taipei Economic and Cultural Representative Office (TECRO) for Taiwan.

The delegations discussed two principal issues: (1) respective procedures for approving foreign investments; and (2) Taiwan's current requirement for financial services firms to host their data on local servers. AIT and TECRO officials discussed with Taiwan's Financial Supervisory Commission (FSC) Chairman, Ming-Chung Tseng, best practices for taking account of views expressed by foreign interests, providing broad market access to foreign investors, and allowing  them to establish investments and conduct business on open and non-discriminatory terms. Relevant sections from the Joint Statement issued by AIT and TECRO following the session are as follows:

Foreign Investment Approvals

Foreign direct investment in non-publicly listed companies requires an approval from the Investment Commission of the Ministry of Economic Affairs (MOEA), under Taiwan's "Statute for Investment by Foreign Nationals." Also, a "Negative List for Investment by Overseas Chinese and Foreign Nationals" (revised on June 17, 2013) indicates prohibited industries and restricted industries.

For investments in regulated industries (e.g., banks, insurance companies, and securities and futures companies), in connection with other circumstances (such as involving or acquiring more than 10 percent of the publicly listed companies' outstanding shares), approval is required by a formal investment committee. In addition, other relevant governing authorities, such as the FSC, the Banking Bureau, the Securities and Futures Bureau, Central Bank, and the Taiwan Stock Exchange Corporation, will provide approval opinions on those regulated industry investments.

With the purpose of creating and maintaining open and stable investment climates, the Joint Statement on Principles for International Investment mentions that both parties should provide the highest possible level of legal certainty and protection against discriminatory, arbitrary, and other unfair or harmful treatment to all investors.

ICT Regulatory Compliance

Taiwan's current regulation requires financial services firms to host their data on local servers. In order to support the development of information technology networks and services, the Joint Statement on Trade Principles for Information and Communication Technology (ICT) includes that governing authorities should not require ICT service suppliers to use local infrastructure, or establish a local presence, as a condition of supplying services.

For more information, contact: Melissa Coyle, Pei-Yi (Ashley) Wang

Hughes Joins CAFC

On September 24, the U.S. Senate voted 98-0 to confirm Todd M. Hughes as a judge on the U.S. Court of Appeals for the Federal Circuit (CAFC). Hughes currently serves as deputy director of the commercial litigation branch of the Justice Department civil division.  

Hughes fills the 12th and final seat on the CAFC, giving the court a full complement of active judges for the first time since 2009. Hughes brings international trade experience in matters before the U.S. Court of International Trade (CIT), experience that should serve well in the CAFC as the court with jurisdiction over appeals from CIT decisions. Hughes earned his law degree from Duke University and his undergraduate degree from Harvard. 

For more information, contact: John Brew, Michael Larmoyeux

CROWELL & MORING SPEAKS

Chris Wilson, John Fuson, and Josh Kallmer will hold a webinar entitled "Free Trade and Regulatory Convergence Across the Atlantic" on October 2, 2013.

John Brew will join a panel on "The Centers of Excellence Debate – How Can Importers Benefit from These Centers?" at the American Conference Institute's 2nd U.S. Customs Compliance Boot Camp, November 19-20, at the Washington Plaza Hotel in Washington, D.C. John is co-chair of the event and Crowell & Moring clients receive a registration fee discount.

CROWELL & MORING WELCOMES

Crowell & Moring welcomes three new Visiting International Scholars:

Eduardo J. Mathison from Araque, Reyna, Sosa, Viso & Asociados, Venezuela. Araque, Reyna, Sosa, Viso & Asociados is a law firm specialized in complex and general professional legal matters. Eduardo earned his law degree, with honors, from Universidad Catolica Andres Bello in 2009; and his LL.M. in international business and economic law from Georgetown University in 2013.

Asli Orhon from Hergüner, Bilgen, Özeke, Turkey. Hergüner, Bilgen, Özeke, founded in 1989, is one of Turkey's largest law firms. Located in Istanbul, they represent and provide legal services to foreign, Turkish and multinational companies, financial institutions, government agencies and multilateral institutions in cross-border business transactions and international law aspects. Asli earned her law degree, with honors, from Galatasaray University, Istanbul, Turkeyin 2008; and her LL.M. in corporate law from Harvard in 2013.

Pei-Yi (Ashley) Wang from Hon Hai Precision Industrial Co., Ltd. (Foxconn Technology Group), Taiwan. Hon Hai Precision Industry Co., Ltd., trading as Foxconn Technology Group, is a Taiwanese multinational electronics contract manufacturing company headquartered in Tucheng, New Taipei, Taiwan. Ashley earned her LL.B. in economic and financial law and LL.M. in economic law from the National Taiwan University in 2004 and 2008, respectively; she also earned an LL.M. with honors, in competition, innovation and information law from New York University School of Law in 2012, and an LL.M. with honors, in international business and economic law from Georgetown University in 2013.

Crowell and Moring's Visiting International Scholars Program (VISP) invites lawyers from abroad to join the firm as consultants for eight months. The program enhances the firm's ability to build relationships with the Scholars' foreign law firms.

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For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

John B. Brew
Partner – Washington, D.C.
Phone: +1 202.624.2720
Email: jbrew@crowell.com
Daniel Cannistra
Partner – Washington, D.C.
Phone: +1 202.624.2902
Email: dcannistra@crowell.com
Jeffrey L. Snyder
Partner – Washington, D.C., Brussels
Phone: +1 202.624.2790, +32.2.214.2834
Email: jsnyder@crowell.com
Melissa Morris
C&M International Director – Washington, D.C.
Phone: +1 202.624.2938
Email: mmorris@crowell.com
Cari N. Stinebower
Partner – Washington, D.C.
Phone: +1 202.624.2757
Email: cstinebower@crowell.com
Maria Alejandra (Jana) del-Cerro
Associate – Washington, D.C.
Phone: +1 202.624.2843
Email: mdel-cerro@crowell.com
Jini Koh
Counsel – New York
Phone: +1 212.803.4065
Email: jkoh@crowell.com
Christopher Monahan
Counsel – Washington, D.C.
Phone: +1 202.624.2529
Email: cmonahan@crowell.com
James (J.J.) Saulino
Associate – Washington, D.C.
Phone: +1 202.624.2717
Email: jsaulino@crowell.com
David (Dj) Wolff
Counsel – Washington, D.C.
Phone: +1 202.624.2548
Email: djwolff@crowell.com
Edward Goetz
Manager, International Trade Services – Washington, D.C.
Phone: +1 202.508.8968
Email: egoetz@crowell.com