Keith Huffman partners with technology, energy, defense, manufacturing, and industrial companies from across the globe to ensure their compliance with US export control regulations, economic sanctions, anti-boycott regulations, anti-corruption laws, and customs laws. He also relies on his years of trade policy lobbying to assist clients with trade policy issues, including free trade agreements, trade legislation, and matters before the World Trade Organization (WTO).
Keith assists US and non-US clients in sanctions matters involving laws administered by the Bureau of Industry and Security (BIS), the Directorate of Defense Trade Controls (DDTC), and the Office of Foreign Assets Control (OFAC). He designs, drafts, and implements customized compliance programs, holds relevant trainings, and advises on compliance-related issues arising from mergers and acquisitions. Keith has conducted numerous internal investigations related to export controls, sanctions, and anti-boycott laws, and provides guidance on US anti-money laundering (AML) and anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA). His work in this area has ranged from providing guidance on suspicious activity report requirements for a money services business to helping conduct independent transaction testing as part of an assessment of a bank’s Bank Secrecy Act (BSA) and AML compliance program. Keith has also helped draft anti-corruption compliance programs and has assisted clients in conducting third party anti-corruption due diligence.
As a registered lobbyist, Keith assisted a manufacturing association in navigating various trade policy issues, such as free trade negotiations, including the Trans-Pacific Partnership (TPP), and various trade preference initiatives, such as the Generalized System of Preferences (GSP) and Miscellaneous Tariff Bills (MTB). He also has significant experience with trade remedy proceedings before the Department of Commerce (DOC) and appeals at the Court of International Trade and the Court of Appeals for the Federal Circuit. Before law school, Keith worked for two years in the US Senate as a legislative correspondent for a member on the Senate Foreign Relations Committee, focusing on trade, defense, and foreign affairs issues, including sanctions, free trade agreements and CFIUS issues.
- District of Columbia
- New York
- US Court of International Trade
- US Court of Appeals, Federal Circuit
- J.D., Catholic University of America, Columbus School of Law, 2011, Comparative and International Law Institute Certificate
- B.A., Trinity College, 2003, History
- Universidad Nacional de Cuyo, 2001, Certificate in Political Science
Areas of Practice
Drafted comprehensive compliance programs for a variety of US and non-US companies regarding compliance with US sanctions laws, including OFAC’s General License H of US Iran sanctions and Cuba sanctions regulations.
Served on a small team assigned to evaluate and test a multinational financial institution’s compliance with AML, BSA, and OFAC statutes and regulations on behalf of a government-appointed independent consultant.
Assisted a client with software export/re-export rules, including de minimis analysis of software with controlled encryption, to enable it to expand exports.
Audited the export compliance of a global security service defense contractor focusing on staffing, hand carries of personal protective equipment, and compliance with export control reform.
Collaborated with local counsel in several countries to conduct due diligence on behalf of a cloud-computing service provider for the import/export of data center equipment and cloud computing services.
Led all facets of an internal investigation, including drafting and submitting a disclosure, regarding violations of the Export Administration Regulations (EAR) and OFAC regulations.
Provided tariff classification recommendations for various items such as gaming kits, computer equipment, and data center equipment.
Coordinated with EU counsel to advise a data storage device company on how to comply with OFAC General License D-1 when selling its products into Iran.
Advised clients on the applicability of certain TPP provisions.
International Law Advisory
June 6, 2018
International Law Advisory
April 12, 2018
By: Lucinda A. Low, Brittany Prelogar, Brigida Benitez, Pablo M. Bentes, William L. Drake, Simon Hirsbrunner, Richard K. Wagner, Alexandra Baj, Rachel B. Peck, Ronak D. Desai, John C. London, Jessica Piquet Megaw, Evan T. Abrams, Elizabeth Arkell, Sara Chouraqui, Melissa Freeman, Elizabeth Pericak Ginsburg, Keith Huffman, Peter Ibrahim, Galen Kast, Peter Jeydel, William W. Simoneaux, A. Cherie Tremaine, Lin Yang, Bo Yue
Super Lawyers, Washington, DC, “Rising Star,” International Law (2016, 2017)
American Bar Association, Export Controls and Economic Sanctions Committee, International Law Section