Areas of Practice
  • The George Washington University School of Law, J.D., 1968, Editor, George Washington Law Review, Order of the Coif
  • George Washington University, A.M., 1966
  • George Washington University, A.B., with distinction and special honors, 1964, Phi Beta Kappa, Valedictorian
Bar & Court Admissions
  • District of Columbia
  • Maryland
  • US Supreme Court
  • US Court of Appeals, Federal Circuit
  • US Court of International Trade
  • US Court of Appeals for the District of Columbia Circuit

Richard O. Cunningham

1330 Connecticut Avenue, NW
Washington DC 20036
TEL: +1 202 429 6434
FAX: +1 202 429 3902


Richard O. Cunningham is senior international trade partner in Steptoe's Washington office. In addition to litigating cases under the US import relief laws, Mr. Cunningham is active in representing corporate and governmental clients with respect to US Government trade policy issues, in negotiating private and governmental agreements to resolve market-access problems and other international trade issues, and in helping clients develop international strategies that take advantage of the trade laws and policies of the United States and foreign governments.  Mr. Cunningham is supported in his international trade work by Steptoe's team of trade law attorneys—one of the largest of any US law firm—comprising 35 attorneys and other professionals.  The group also draws as needed from the skills of attorneys in Steptoe's other practice areas, comprehensively covering US and EU regulatory matters and the full range of litigation and arbitration.

United States Import Relief Laws
Mr. Cunningham handled many of the major US antidumping and countervailing duty cases of the last three decades.  In antidumping cases, he is known particularly for his experience in proceedings involving complex manufactured products and multi-layered distribution systems, and for cases involving imports from non-market economies and economies in transition.  Under the countervailing duty law, Mr. Cunningham has particular experience in cases involving capital subsidies, privatization, research and development subsidies, and subsidy aspects of agricultural trade.  He is also known for achieving negotiated resolutions of import relief proceedings.

In addition to litigating cases, Mr. Cunningham regularly advises foreign exporters as to how they may reduce their vulnerability to US import relief cases, and counsels foreign governments on how supports may be structured so as to comply with WTO rules and US countervailing duty laws.  He also represents clients in connection with proposed antidumping and countervailing duty legislation in the United States and in other countries, and in connection with the negotiation of international rules governing import relief proceedings.

Trade Policy Issues
On behalf of both US and foreign clients, Mr. Cunningham provides advice and advocacy with respect to international trade policy decisions by the United States and other governments.  Such representations involve bilateral and multilateral trade negotiations, decisions in discretionary trade law cases, market-access initiatives, legislation and governmental policies in such trade-related areas as intellectual property, government procurement, standards, export controls, taxation and issues relating to trade in services.  He advised the Korean Government in their FTA negotiations with both the United States and the European Union, and has since counseled the Korean Government on issues relating to several other FTA negotiations as well as bilateral and multilateral disputes.  He also represented the Mexican Confederation of Industries in the NAFTA negotiations.  As a result of Mr. Cunningham's involvement in trade policy issues, he has been asked on numerous occasions to advise Congressional committees and governmental agencies on international trade issues.

World Trade Organization Matters
Mr. Cunningham was active on behalf of clients in the Tokyo, Uruguay and Doha Rounds of Multilateral Trade Negotiations.  He frequently represents corporate clients, and occasionally advises governments, in World Trade Organization (WTO) dispute resolution proceedings.  He has particular experience in bringing about negotiated resolutions of disputes arising under the WTO Agreements.

Development of International Trade Strategies
Drawing on his international trade law experience and his long-standing relationships with trade policy officials in the United States and foreign governments, Mr. Cunningham regularly assists corporate clients in devising international trade strategies.  Such advice seeks to enable the client to integrate international marketing, pricing, and plant siting decisions with the laws and policies of relevant governments.  Strategies are developed to overcome obstacles to market access, to utilize trade laws and cases for commercial advantage, to maximize the advantages of intellectual property rights or proprietary technology, and to obtain assistance or protection from domestic and foreign governments.


  • Named "Senior Statesman" in International Trade: Trade Remedies & Trade Policy (US) by Chambers Global 2008, 2010, 2015, and 2017: The World's Leading Lawyers for Business
  • Band 1, Chambers Global, International Trade: Trade Remedies & Trade Policy (US), 20092011-2014
  • Named "Senior Statesman" in International Trade: Trade Remedies & Trade Policy (Nationwide) by Chambers USA 2008: The World's Leading Lawyers for Business
  • Chambers USA; International Trade: Trade Remedies & Trade Policy (Nationwide), 2010-2016
  • Washington, DC Super Lawyers, International, 2008-2017
  • Best Lawyers in America, International Trade and Finance Law, 2003-2018 
  • Legal 500 Hall of Fame 2017
  • Leading Lawyer, Legal 500 US, Dispute Resolution: International Trade, 2016-2017
  • Leading Lawyer, Legal 500 US, Litigation: International Trade, 2014
  • The Legal 500 US, Litigation: International Trade, 2008-2016
  • Who's Who Legal for Trade & Customs, 2009-2013
  • Listed in Ethisphere’s 2009 and 2010 Attorneys Who Matter for Trade/Export Compliance
  • Euromoney's Expert Guide to the World's Leading International Trade Lawyers (2007, 2008, 2010, 2015)
  • Euromoney's Expert Guide to The Best of the Best (2008, 2010)
  • Euromoney's Expert Guide to The Best of the Best USA (2008, 2010)

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Selected Publications

Professional Affiliations

  • Section of International Law, American Bar Association
  • Section of Antitrust Law, American Bar Association
  • Section of Public Contract Law, American Bar Association
  • Section of Litigation, American Bar Association
  • Chair, Cordell Hull Institute
  • Executive Committee, Canada-United States Law Institute
  • Advisory Board, Global Business Dialogue
  • Past Chair, Standing Committee on Customs Law, Committee on International Litigation, Litigation Section, American Bar Association