Overview
Jack Hayes provides advice to clients regarding US economic sanctions, anti-money laundering, counter-terrorist financing, export controls, anti-boycott, and anti-corruption laws and regulations.
Jack has conducted internal investigations and handled defense of civil and criminal enforcement cases, as well as regulatory notification matters. His practice involves representing clients before various U.S. government agencies, including the Office of Foreign Assets Control, Financial Crimes Enforcement Network, Directorate of Defense Trade Controls, Bureau of Industry and Security, Office of Antiboycott Compliance, Defense Technology Security Administration, Defense Counterintelligence and Security Agency, National Nuclear Security Administration, Nuclear Regulatory Commission, the Department of Justice's Criminal Division, National Security Division, and Bureau of Alcohol, Tobacco, Firearms, & Explosives, and Customs and Border Protection.
His practice includes advising on know-your-customer procedures and due diligence best practices, developing contractual and other safeguards, and analyzing international trade and financial compliance legal risks associated with investments, acquisitions, divestments, transfers, transactions, and other dealings. Jack helps clients evaluate jurisdiction and classification of items, defense articles, defense services, or brokering under the International Traffic in Arms Regulations and Export Administration Regulations and prepares license applications, advisory opinions, and private letter ruling requests. He also conducts gap assessments of clients' operations or compliance programs; establishes or enhances existing compliance programs, policies, or procedures; tests compliance systems and internal controls; and provides training in related areas.
- District of Columbia
- Maryland
- J.D., Northwestern University School of Law, 2003, Associate Editor, Northwestern University Law Review
- B.A., Furman University, 1998, magna cum laude, Phi Beta Kappa
Areas of Work
Speaking Engagements
- "The Impact of Global Economic Sanctions: a Sword or a Shield, and for Whom?" 33rd Annual Meeting and Conference of the Inter-Pacific Bar Association (IPBA), April 24, 2025
- IPBA Annual Meeting in and Conference in Tokyo, April 26, 2024
- "Key US Economic Sanctions & Export Control Considerations for the Natural Gas Industry," 4th Energy Transition Forum 2023, Washington, DC, December 6, 2023
- "ITAR Compliance in Practice: The Core Elements of an Effective Program, Due Diligence and Supply Chain Management," ACI’s Building Blocks for ITAR Proficiency, November 7, 2023
- "The Core Elements of an Effective ITAR Compliance Program, Due Diligence and Supply Chain Management," ACI's Building Blocks for ITAR Proficiency, February 21, 2023
- "Foreign, Dual and Third Country Nationals, and Technology Transfers," ACI's ITAR Proficiency Series, February 8, 2022
- "ITAR Compliance in Practice: The Core Elements for Your Program, Due Diligence and Supply Chain Management," Passport to Proficiency on the ITAR, ACI Proficiency Series, April 26, 2021
- "Export Controls and Sanctions," The Global Trade Academy: Legal Foundations, Review and Reform of the Global Trading System, Georgetown University Law Center’s Institute of International Economic Law (IIEL), March 26, 2021
- "Legal Foundations & New Directions of the Global Trading System: Economic Sanctions, Export Controls, Anti-Corruption, & Transparency Requirements," Georgetown University Law Center's Global Trade Academy, Washington, DC, February 14, 2020
- "How to Meet the Top 10 Classification Challenges for Canadian Organizations," ACI/CI's 9th Forum on US Export & Reexport Compliance For Canadian Operations, Toronto, Canada, January 28, 2020
- "US Economic Sanctions Affecting the Oil & Gas and Energy Industry," 5th Washington Oil & Gas Forum 2019, Washington, DC, June 6, 2019
- "OFAC Sanctions," Lockheed Martin 2019 Corporate International Trade Compliance Conference, Bethesda, MD, April 2, 2019
- "Blockchain 101: What You Need to Know," 2019 Lex Mundi North America Regional Conference, Atlanta, GA, March 8, 2019
- "Export Controls, Sanctions and Transparency Requirements," The Global Trade Academy: Legal Foundations and New Directions of the Global Trading System, Georgetown University Law Center and Institute of International Economic Law (IIEL), Washington, DC, February 15, 2019
- "ITAR and EAR Classifications: Focus on Foreign Persons Subject to the ITAR Licensing and Exemptions," CI's US Export and Re-Export Compliance for Canadian Operations, Toronto, Canada, January 30, 2019
- "Financial Crimes Outside the US: Money Laundering, Blockchain/Cryptocurrency, and Sanctions Enforcement," National Association of Criminal Defense Lawyers’ 8th Annual West Coast White-Collar Conference, Santa Monica, CA, June 21, 2018
- "European-American Gas Developments: What are the Prospects for Cooperation?," 4th Annual Oil and Gas Forum, Washington, DC, June 6, 2018
- Moderator, "How to Establish Thresholds for Risk, Detect and Report Potential Laundering and Fraud," 8th Annual Forum on AML & OFAC Compliance for the Insurance Industry, New York, NY, January 23, 2018
- "Export Controls, Sanctions, and Transparency Requirements," Georgetown Law Institute of International Economic Law, Washington, DC, November 17, 2017
- "The Challenge: Meeting Global Infrastructure Investment Needs," Infrastructure Diplomacy Forum & Roundtable, Washington, DC, November 2, 2017
- "New Intermodal Connections and the Maritime Silk Road: International Regulation & Compliance Considerations," New Silk Road Summit, Washington, DC, October 4, 2017
- "Keeping Pace with a Changing Regulatory Landscape," Global Legal Compliance ConfEx, Washington, DC, April 26, 2017
- "Best Practices for Preparing for an ITAR Audits," C5 Annual Conference on US Trade Controls Compliance in Europe, London, UK, February 1, 2017
- "International Compliance Issues for CGIAR," Consultative Group on International Agricultural Research webinar, January 25, 2017
- "Export Controls and Economic Sanctions," Georgetown Law Academy: Legal Foundations and New Directions, the WTO, & Beyond, Washington, DC, November 18, 2016
- "ITAR Compliance: A Voluntary Disclosure and Best Practices Workshop," Federal Publications Seminars, Arlington, VA, October 26, 2016
- "Focus on Cuba: Clarifying How the Remaining US Sanctions Still Conflict with Canadian Law," ACI's Canadian Forum on Economic Sanctions Compliance & Enforcement, Toronto, Canada, October 5, 2016
- "Intermodal and Maritime Connections," Silk Road Summit & Business Forum, Washington, DC, September 26, 2016
- "How Economic Sanctions Apply to US and Non-US Extractive Operations, and How to Manage These Risks," 62nd Annual Rocky Mountain Mineral Law Institute, Squaw Valley, CA, July 21, 2016
- "Your Licensing Toolkit: How to Obtain the Licenses You Need and Work Effectively with Licensing Agencies," C5 Exporter's Forum on Global Economic Sanctions, Amsterdam, The Netherlands, May 18, 2016
- International Trade Roundtable, US-Kazakhstan Business Association, Washington, DC, December 8, 2015
- "ITAR Compliance: Voluntary Disclosures and Best Practices Workshop," Federal Publications Seminar, Arlington, VA, October 25, 2015
- "Iran Sanctions and the Insurance Industry," American Insurance Association, August 5, 2015
- "Iran Sanctions and the Reinsurance Industry," Reinsurance Association of America, July 30, 2015
- "Creating a New Product with US Defense Controlled Materials," C5's US Defense Trade Controls Under Commerce and State, London, UK, January 22, 2015
News & Publications
Stepwise Risk Outlook
US Intelligence’s 2025 Worldwide Threat Assessment; Implications for Businesses
April 2, 2025
By: Melissa B. Mahle
International Compliance Blog
Trump Imposes Novel “Secondary Tariffs” on Countries Importing Venezuelan Oil and Petroleum Products
March 31, 2025
By: Steptoe's Economic Sanctions Practice
International Compliance Blog
Treasury Department Delists Tornado Cash Following the Fifth Circuit’s Decision
March 25, 2025
By: Steptoe's Economic Sanctions and Blockchain and Cryptocurrency Practices
Stepwise Risk Outlook
First Steps Towards Ending the Ukraine War Highlight Difficult Process and Business Risks Ahead
March 5, 2025
By: Melissa B. Mahle
Press Releases
Steptoe Clients KEPCO and KHNP Settle Dispute with Westinghouse Electric
January 29, 2025
Stepwise Risk Outlook
December 8, 2024
Stepwise Risk Outlook
Georgian Dream Puts Breaks on EU Accession, Escalating Geopolitical Risks
December 5, 2024
By: Melissa B. Mahle
Client Alerts
December 5, 2024
Stepwise Risk Outlook
Mexico’s Role in the US-China Trade Landscape: US Partner or Chinese Backdoor?
December 3, 2024
By: Anni Coonan
Stepwise Risk Outlook
Great Power Competition in the Arctic: Implications for International Trade
November 7, 2024
By: Melissa B. Mahle
Resources
Client Alerts
China's New Blocking Rules May Impact US Sanctions and Export Control Compliance Strategies for Many
February 10, 2021
By: Edward J. Krauland, Bo Yue
Client Alerts
Sanctions Under the Biden Administration: A Return to 'Smart?'
November 24, 2020
By: Edward J. Krauland, Meredith Rathbone, Wendy Wysong, Jack R. Hayes, Evan T. Abrams, Martin Willner, Jordan Cannon (Law Clerk)
Client Alerts
Commerce Issues Long-Awaited Export Control Rules for China, Russia, and Venezuela
April 30, 2020
By: Edward J. Krauland, Wendy Wysong, Meredith Rathbone, Alexandra Baj, Jack R. Hayes
Client Alerts
US and EU Sanctions Policies on Humanitarian Exports and COVID-19 Relief
April 6, 2020
By: Wendy Wysong, Ali Burney, Edward J. Krauland, Meredith Rathbone, Guy Soussan, Jack R. Hayes
Client Alerts
FinCEN Penalizes Compliance Officer for Anti-Money Laundering Failures
March 24, 2020
By: Zoe Osborne, Jack R. Hayes
Client Alerts
EU Issues Guidance on Internal Compliance Programs for Dual-Use Trade Controls
November 6, 2019
By: Guy Soussan, Jack R. Hayes
Client Alerts
PdVSA Sanctions Designation Has Significant Implications for US Business
February 14, 2019
By: Edward J. Krauland, Meredith Rathbone, Jack R. Hayes, Evan T. Abrams
Client Alerts
President Imposes First US Economic Sanctions Against Venezuelan Digital Currency
March 26, 2018
Client Alerts
Criminal Enforcement and Significant Penalties Continue in 'Big Bank' AML Cases
March 23, 2018
By: Jack R. Hayes
Events
Webinars
March 14, 2025
Webinars
The Steptoe Update: US, EU, and UK Legal Developments Affecting Asian Companies and Public Actors
December 11, 2024
Speakers: Lee Berger, Eric C. Emerson, Jack R. Hayes, Charles Whiddington
Webinars
2015 Developments Regarding Economic Sanctions and Export Controls
December 15, 2015
Speakers: Alexandra Baj, Jack R. Hayes, Meredith Rathbone, Edward J. Krauland
Noteworthy
- Super Lawyers, Washington, DC, "Rising Star," International (2015)
Professional Affiliations
- American College of Investment Counsel
- Rocky Mountain Mineral Law Foundation
- American Society of International Law