Services/About

Our firm advises companies, regional law firms, and other professional advisers on strategies dealing with trade and investment into the North American area, and on U.S. sanctions, export controls, and related cross-border compliance issues throughout the world.

Within that broad area, and specifically, we advise Southeast Asian companies and lawyers who must deal with the opportunities and dangers brought on by new geopolitical realities.

The opportunities arise primarily from becoming intermediaries in trade that formerly occurred directly between other countries, such as between China and the United States.

 The dangers arise from the propagation of sanctions and trade control laws imposed primarily by the United States, but far from exclusively.

New supply chain structures

The new geopolitical realities have already changed global trade patterns between Southeast Asia and North America. Between April 2, 2025 (the “Liberation Day” of tariff changes announced by the Trump administration), there is significantly:

• Less direct trade between the U.S. and China,

• More trade between China and Southeast Asia,

• More trade between Southeast Asia and the North American economic area, including Mexico.

We see Southeast Asian companies participating in these new trading patterns, and, with time, in new direct investments.

Sanctions Compliance Programs

We can also work with Southeast Asian companies in their wider compliance with U.S. sanctions and trade-control programs.

A company’s adoption and implementation of a Sanctions Compliance Program (SCP) is one of the best ways of avoiding problems with U.S. enforcement agencies, and is accordingly a large part of the value we can render to Southeast Asian companies and their lawyers.

A Sanctions Compliance Program refers to an individual plan a company creates and implements following an assessment of its business and practices. A Thai manufacturer of auto parts buying from two vendors and selling to one purchaser will have a very different risk profile than, say, a Malaysian electronics component assembler purchasing from 90 suppliers in 8 different countries, and selling to 25 intermediate purchasers in six different countries on three continents. In the second case, the probability that the Malaysian manufacturer is using components originating from the U.S. or China, or selling to entities in those two countries, can almost be assumed.

A client’s vendors’ and buyers’ profiles also play an important part of such analysis. Do many of the entities the client deals with come from countries or regions associated with sanctions violations, or are the objects of sanctions themselves?

Are many of the client’s purchasers unknown foreign companies with no apparent connection to the subject matter of the transaction. A purchaser of a $15 million order of sophisticated electronics whose name includes the word “Bakery” may not be the final end-user, and the fact that such a transparently suspicious intermediary has been usd may itself evidence an intent to evade sanctions.

The care a company takes in assessing its own risks, and in crafting and implementing a program the truly responds to them, is often the best predictor of its success in avoiding sanctions. What companies should avoid are the two extremes, one, either of having no program at all, or two, of adopting an overly broad “one-size-fits-all” program that has no realistic chance of being carried out in its day-to-day operations or, if carried out, at a ridiculous cost to its efficiency and bottom line.

Our firm knows international business and U.S. law well enough to assess and assign risk to a client’s business, and recommend compliance programs tailor made to those circumstances.

1. To a Vietnamese manufacturer who incorporates Chinese components into products its ships to Mexico, for further processing and incorporation into final articles exported to the United States, we could say, please do this.

2. To a Malaysian trading company in petroleum products, we could say, don’t worry about that but please do this.

3. To yet another company who has one well-known supplier, and one well-known purchaser, the recommended plan might involve minimal intrusion into the company’s procedures.

Our special expertise in Mexico

Our professional experience in Mexico goes back more than three decades, to the adoption of the North American Free Trade Agreement (NAFTA) which brought the U.S., Canada and Mexico into a trading and investment bloc. Since then, over 50% of our practice has been representing U.S., European, and Asian companies establishing footholds in Mexico. We have represented our clients’ interests in 28 of the 31 states, and especially in the northern industrial states of Chihuahua, Baja California, Nuevo Leon and Tamaulipas.

This experience allows us to combine critical legal, logistical, customs, labor, and geographical concerns, giving our clients an ability to see the entire forest before they enter it.

Numerically we are a small practice, serving smaller companies, and we like to keep it that way. In some cases, a new entry into the North American market will require a larger firm in a variety of disciplines, not just the law. We are excellent in advising clients when that is necessary, when it is not, and how to go about it.

Our goal is to deliver strategic advice to smaller companies entering the North American market, especially through Mexico.

Working with Regional Counsel

We also work with law firms in Southeast Asia, Mexico, and other jurisdictions that require U.S. sanctions or export-control support for their clients.

Our role may be limited to a specific U.S.-law issue or may continue throughout a transaction, investigation, compliance project, or advisory relationship. The objective is to provide the required U.S. legal component without unnecessarily displacing the regional firm or complicating its relationship with the client.