David (Dj) Wolff

Partner; Attorney at Law
Washington, D.C.London
djwolff@crowell.com
Phone: +1 202.624.2548
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595
Phone: +44.20.7413.1368
Tower 42
25 Old Broad Street
London, EC2N 1HQ
United Kingdom

David (Dj) Wolff is a partner and attorney at law in the firm's Washington, D.C. and London offices and a director with C&M International, the firm's trade policy affiliate

At Crowell & Moring, he practices in the International Trade practice group where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations, including by providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws which can arise from the interaction between extraterritorial impacts of U.S. regulations and third country "blocking" laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.

Dj also works as a director with Crowell & Moring's affiliate, C&M International, where he assists clients with international market access issues and represents clients through the multinational negotiation and national implementation of treaties, as well as in the development and advancement of initiatives through the Asia-Pacific Economic Cooperation (APEC) Forum. 

Dj was selected as one of the National Law Journal’s “DC Rising Stars” in 2019, and was identified as one of the "Future Leaders" by Who's Who Legal: Investigations in 2018 and 2019, one of the "40 under 40" in Investigations internationally by the Global Investigations Review in 2017, and one of the five finalists for the WorldECR Young Practitioner of the Year award in 2016.

Dj’s recent significant matters include:

Economic Sanctions Counselling

  • Secured successful closure of OFAC subpoena without penalty relating to a review of U.S. service provider’s compliance with Russia-related “sectoral” sanctions.
  • Conducted week-long intensive sanctions training for more than 300 bank compliance officers in four countries on three continents over the course of three months. 
  • Implemented sanctions-screening system for U.S. manufacturer’s global operations, including designing the internal policies and procedures, training the internal compliance teams, and managing the review, escalation, and disposition of potential matches. 
  • Seconded to EU based financial institution’s branch office in Dubai to serve as in-house sanctions counsel providing daily guidance on sanctions-related compliance and investigation matters.
  • Represented, including through direction of local counsel across three jurisdictions, a multinational manufacturer in response to a criminal inquiry from the Russian customs authority related to exports to Russia.
  • Served, in collaboration with a U.K. colleague, as expert witnesses related to U.S. and U.K./EU economic sanctions, in litigation in Scotland, on behalf of a Scottish firm, related to the largest professional negligence claim ever filed in Scotland.
  • Seconded to federally-regulated U.S. financial institution as its Global Economic Sanctions Compliance Leader responsible for overseeing a worldwide economic sanctions compliance program and a team of experts covering numerous third country subsidiaries and millions of annual transactions and customers.
  • Led internal investigation for a U.S. manufacturer of activity undertaken by a newly acquired subsidiary in potential violations of U.S. and EU economic sanctions and export controls involving a team of lawyers in the U.S., United Kingdom, and Brussels.
  • Collaborated with U.S. and EU data privacy colleagues to represent a non-U.S. subsidiary of a U.S. financial institution in a petition to the French Data Privacy authority for authorization to conduct screening for sanctions compliance against certain types of personal identifying information.
  • Represented U.S. manufacturer of equipment used in refineries and downstream oil and gas facilities in reviewing all potential transactions for compliance with U.S. and EU blocking and sectoral sanctions on Russia.
  • Represented a multinational publishing company with respect to the scope of the exemptions and authorizations related to informational material and publishing services for countries subject to U.S. embargo.
  • Assisted in the internal review and development of a prospective trade compliance plan for a multinational service provider’s back-office support for its non-U.S. customers potentially doing business in sanctioned countries.
  • Conducted due diligence on a potential target company’s compliance with U.S. economic sanctions and export controls on behalf of a U.S. private equity firm in a successful $1.4 billion acquisition.

Export Controls & Antiboycott

  • Represented a U.S. manufacturer in negotiations with the Bureau of Industry and Security (BIS) and Customs and Border Protection (CBP) to secure release of oil and gas equipment improperly seized before export to Russia.
  • Secured commodity jurisdiction determination from the Department of Defense Trade Controls (DDTC) for a U.S. manufacturer to confirm its product was not subject to the International Traffic in Arms Regulations (ITAR).
  • Prepared a series of commodity classification requests (CCATS) for a U.S. manufacturer.
  • Represented a U.S. financial institution in an internal investigation and voluntary disclosure to the U.S. Commerce Department of potential violations of the U.S. antiboycott regulations.
  • Prepared quarterly and annual antiboycott reports for the Commerce Department and the Treasury Department for U.S. manufacturer.

Import, Customs, and Trade Preference Program Implementation

  • Represented a multinational well services provider in a successful Court of International Trade (CIT) litigation and Federal Circuit appeal to overturn CBP's proposed customs classification and secure duty-free treatment of an imported product, resulting in millions in duty savings.
  • Represented a U.S. consumer goods company in a petition to add new products to the list of those eligible for duty free importation under the Generalized System of Preferences (GSP).
  • Represented a U.S. chemical manufacturer in a global review of its supply chain to optimize usage of U.S. and non-U.S. free trade agreements (FTAs) including NAFTA and KORUS and regional free trade agreements (RTAs) including those negotiated by ASEAN.

International Trade Policy and Multilateral Institutions

  • Represented a wide range of U.S. associations in developing and advancing public-private initiatives in the Asia-Pacific Economic Cooperation Forum (APEC), including in-person meetings in China, Indonesia, Papua New Guinea, Peru, the Philippines, and Vietnam.
  • Represented a U.S. trade association in negotiations with the European Commission regarding market access and regulatory cooperation aspects of the potential Trans-Atlantic Trade and Investment Partnership (TTIP).
  • Represented a trade association during negotiating sessions of the World Intellectual Property Organization (WIPO) Intergovernmental Committee on Intellectual Property and Genetic Resources, Traditional Knowledge and Folklore.
  • Coordinated a “roadshow” and in-person meetings for a U.S. trade association in countries party to the Trans-Pacific Partnership (TPP) during the TPP’s negotiations.

Pro Bono

  • Represented a non-profit in securing the first-ever public exemption granted by the United Nations Security Council’s 1718 Committee from North Korea related sanctions to a non-UN affiliated body.
  • Secured OFAC and BIS licenses for U.S. non-profit to undertake multi-drug resistant tuberculosis treatment involving U.S. persons and U.S. products in North Korea.
  • Prepared training on compliance with U.S. sanctions, export controls, and anti-corruption legislation for a U.S. non-profit providing in-person tuberculosis and AIDS treatment around the world.
  • Argued in front of the D.C. Circuit as amicus appointed by the Court in support of a D.C. inmate’s suit for damages against U.S. Parole Commissioners
  • Represented DC inmate in Innocence Project motions and subsequent parole board hearings, ultimately resulting in the client’s successful release on parole.
  • Coordinated C&M’s weekly tutoring program for the Thurgood Marshall Academy, a charter high school with a pre-law focus based in Anacostia.


Affiliations

Admitted to practice: District of Columbia, New York, the Court of International Trade, the Federal Circuit, and the U.S. Court of Appeals for the D.C. Circuit



Highlights, News & Knowledge


Speeches & Presentations

  • "Sanctions: Current Focus and Potential Changes," Managing Regulatory & Compliance Challenges in Shipping Seminar, London, UK (September 27, 2019). Speakers: Michelle J. Linderman and David (Dj) Wolff.
  • "Sanctions on North Korea and the Humanitarian Exemptions Process," 2018 International Conference on Humanitarian and Development Assistance to the DPRK, Seoul, South Korea (October 31, 2018). Presenter: David (Dj) Wolff.
  • "OFAC Compliance: Considerations for the Hotel Industry," 2018 Hotel and Lodging Legal Summit, Washington, D.C. (October 26, 2018). Presenter: David (Dj) Wolff.
  • "The Impact of U.S. and UN Sanctions on Humanitarian Work in the DPRK," National Assembly Building, Seoul, South Korea (June 20, 2018). Presenter: David (Dj) Wolff.
  • "Sanctions in Year Two of the Trump administration: Russia, Iran, North Korea, and beyond," Trade in 2018 - What's Ahead?, Webinar (April 19, 2018). Presenters: Cari N. Stinebower, Michelle J. Linderman and David (Dj) Wolff.
  • "Risky Business - International Commerce Under Stress: Russia, Cuba, and Qatar," Crowell & Moring Webinar (July 18, 2017). Speakers: Cari N. Stinebower, David (Dj) Wolff, and Mariana Pendás.
  • "Suspicious Activity Reporting, 'Know Your Customer' Protocols, and Information Sharing: Detecting and Reporting on Potential Laundering or Fraudulent Activities and Overcoming the Challenges of Identification, Including Cases Involving Elder Exploitation," 7th Annual Forum on AML & OFAC Compliance for the Insurance Industry, New York, NY (January 19, 2017). Speaker: David (Dj) Wolff.
  • "This Year in Trade – What's Ahead in 2017?" Webinar, Crowell & Moring's First 100 Days Series (January 18, 2017). Presenters: Benjamin Blase Caryl, Paul Davies, Maria Alejandra (Jana) del-Cerro, Charles De Jager, Carlton Greene, Robert L. LaFrankie, Aaron Marx, James (J.J.) Saulino, Alexander H. Schaefer, and David (Dj) Wolff.
  • "Update on CBP's Forced Labor Detentions," Webinar (July 20, 2016). Presenters: Frances P. Hadfield and David (Dj) Wolff.
  • "Venezuela Update Webinar: Exchange Controls and Possible International Remedies to Recover Stranded Funds, and OFAC Sanctions," Crowell & Moring Webinar (June 22, 2016). Speakers: Ian A. Laird, Eduardo Mathison, Melissa Morris, David (Dj) Wolff, and Pedro L. Planchart.
  • “This Year in Trade: Economic Sanctions,” Crowell & Moring Webinar (March 16, 2016). Speaker: David (Dj) Wolff.
  • "Practical Implications of Instituting an OFAC-Ready Global Sanctions Compliance Program," The WorldECR Export Controls & Sanctions Forum 2015, London, UK (October 14-15, 2015). Presenter: David (Dj) Wolff.
  • “This Year in Trade: Economic Sanctions,” Crowell & Moring Webinar (October 8, 2015). Speaker: David (Dj) Wolff.
  • "Export Controls, Economic and Trade Sanctions: The Challenges and Risks," Thompson Information Services Webinar (September 24, 2015). Presenters: Adelicia R. Cliffe, Christopher Monahan, Maria Alejandra (Jana) del-Cerro, and David (Dj) Wolff.
  • "Practical Implications of Instituting an OFAC-Ready Global Sanctions Compliance Program," The WorldECR Export Controls & Sanctions Forum 2015, Washington, D.C. (September 21-22, 2015). Presenter: David (Dj) Wolff.
  • "This Year in Trade - What's Ahead in 2015: Export Controls," Crowell & Moring Webinar (February 10, 2015). Presenters: Dr. Salomé Cisnal de Ugarte, Christopher Monahan, Maria Alejandra (Jana) del-Cerro, and David (Dj) Wolff.
  • "Beyond Nagoya: Access and Benefit Sharing Requirements in the EU and WIPO," Personal Care Products Council Annual Legal and Regulatory Conference (April 2014). Presenter: David (Dj) Wolff.
  • "Export Controls, Economic and Trade Sanctions: The Challenges and Risks," L2 Federal Resources Webinar (January 30, 2013). Presenters: Adelicia R. Cliffe, James (J.J.) Saulino, and David (Dj) Wolff.
  • "Avoiding Anti-Corruption Violations During Customs Transactions" C5's 7th Annual Advanced Forum on Global Customs Compliance, in Brussels, Belgium (May 23-24, 2012). Co-Speakers: David (Dj) Wolff, Alan W. H. Gourley and Laurent Ruessmann.


Publications



Client Alerts & Newsletters



In the News



Firm News & Announcements

Jul.26.2019 The National Law Journal Names Partner David (Dj) Wolff a D.C. Rising Star for 2019
Jan.03.2019 Crowell & Moring Elects Eight New Partners and Promotes 21 Associates to Counsel
Aug.17.2018 Crowell & Moring Listed as 'Highly Commended' for Sanctions Work in 2018 WorldECR Awards
Sep.13.2017 Crowell & Moring’s Dj Wolff Named to Global Investigations Review's “40 Under 40” List
Aug.07.2017 Two East Asia Companies Dismiss Lawsuit against FBI
Oct.14.2016 Crowell & Moring Named a Top Firm for Serving Latin America by Latinvex
Jan.04.2016 Crowell & Moring Elects Nine New Partners and Promotes 15 Associates to Counsel
Oct.15.2015 Crowell & Moring Participates in Initiative to Combat Art Industry Fraud