David (Dj) Wolff, Counsel Washington, D.C.
djwolff@crowell.com
Phone: +1 202.624.2548
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

David (Dj) Wolff is a counsel in the firm's Washington, D.C. office and a consultant 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. Dj works with U.S. and non-U.S. clients with respect to all aspects of these regimes, including by developing compliance programs, representing them during enforcement and investigation proceedings, conducting internal investigations, responding to government inquiries, and managing the potential conflict of laws which can arise from the conflicting requirements of U.S. regulations and third country "blocking" laws or data privacy regulations. 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 consultant 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. 

In 2016, Dj was one of five finalists globally for the WorldECR Young Practitioner of the Year award.

Dj’s recent significant matters include:

Economic Sanctions Counseling

  • 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.
  • Provided guidance to a non-U.S. financial institution on the scope of debt and equity restrictions under U.S. sectoral sanctions applicable to Russia.
  • 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 to overturn customs classification and secure duty-free
  • 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, 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

  • 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.
  • Represented DC inmate in Innocence Project motions and subsequent parole board hearings.
  • 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

  • "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.


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In the News



Firm News & Announcements

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
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