D. Michael Cormaney

Mr. Cormaney specializes in advising clients on a broad range of international trade compliance matters. In his primary practice area of export controls, Mr. Cormaney assists clients of all sizes – both U.S. and foreign – with issues involving compliance with the ITAR, EAR, and OFAC sanctions regulations, such as:

● Registration and jurisdiction/classification issues (e.g., Commodity Jurisdictions and CCATS);

● Preparation of license applications and ITAR Part 124 Agreements, as well as implementation and management of approvals;/

● Addressing and analyzing compliance issues, including internal investigations, preparation of voluntary/directed disclosures, and responses to subpoenas;

● Internal compliance audits and reviews, including due diligence reviews related to acquisitions, mergers or divestments to identify potential export compliance issues that may affect the timing or terms of a proposed transaction;

● Developing and implementing export compliance policies and procedures that reflect industry “best practices” and that are customized for a company’s existing operations; and

● Training on all aspects of export compliance – ranging from overview/refresher training to targeted training sessions addressing issues of particular concern for specific groups/departments.

Mr. Cormaney also advises clients on regulatory compliance and security matters that often intersect with export controls, such as (i) customs matters (e.g., classification, valuation, country of origin, seizures and other enforcement actions); (ii) obtaining facility clearances and personnel security clearances, including “foreign ownership, control and influence” mitigation measures and appeals of security clearance denials; (iii) counseling U.S. and foreign companies on requirements applicable to foreign direct investment maintained by the Committee on Foreign Investment in the United States (“CFIUS”); and (iv) requirements imposed on transactions under the U.S. Foreign Military Financing (FMF) program.
Mr. Cormaney started his legal career in 1997 in the Washington, D.C. office of Arnold & Porter. From June 2001 to June 2003, he served as the Senior Advisor to the Under Secretary of Commerce for Industry and Security at the U.S. Department of Commerce, where he was integrally involved in the development, formulation, interagency coordination and implementation of U.S. laws, regulations, and policies involving national security and foreign policy controls on the export of “dual-use” items and technologies – with particular emphasis on U.S. policy toward India and U.S. participation in the multilateral export control regimes.
Mr. Cormaney served for 10 years as a member of the Defense Trade Advisory Group (DTAG), which is a federal advisory committee that provides guidance to the State Department on issues involving U.S. laws, policies, and regulations for munitions exports. He also served as a member of the President’s Export Council, Subcommittee on Export Administration (PECSEA), the senior advisory committee to the U.S. Department of Commerce on export controls He holds a J.D. from the University of Iowa College of Law and is a member of the District of Columbia Bar.