Ammon R. Hansen

International Law – Export Controls, International Trade Compliance, and Anti-Corruption

• Conducts internal investigations for alleged violations of International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Foreign Corrupt Practices Act (FCPA), other government regulations, and company policies and procedures.
• Drafts disclosures (mandatory and voluntary) to various federal government agencies, including the U.S. State Department’s Directorate of Defense Trade Controls (DDTC), the U.S. Department of Commerce’s Office of Export Enforcement (OEE), the Department of Justice (DOJ), and other agencies.
• Reviews applicant licenses and supplier sales for compliance with ITAR part 130 (political contributions, fees, and commissions), and advises on compliance with ITAR part 129 (brokering).
• Assists companies with determining the root cause of export violations and helps develop and implement corrective actions to prevent future violations.
• Conducts audits of company manufacturing license agreements (MLAs), technical assistance agreements (TAAs), and licenses for compliance with ITAR regulations.
• Drafts policies and procedures (domestic and international) related to export matters and international supply chain issues.
• Provides training for companies related to export controls and compliance, anti-corruption, policy compliance, ethics, and government regulations.
• Leads risk-based due diligence reviews and assessments of international third parties/suppliers, including review of compliance with anti-corruption laws (e.g., FCPA, UK Bribery Act) and other regulatory requirements to identify and address red flags.
• Reviews special financing plans with suppliers (e.g., performance based payments [PBPs], milestone payments, progress payments) to identify risk and ensure anti-corruption compliance.

Investigations, Government Inquiries, and Subpoenas

• Assists companies and individuals dealing with government investigations, grand jury and document subpoenas, search warrants, criminal prosecutions, and other government inquiries.
• Conducts internal investigations for businesses dealing with potential criminal conduct (e.g., employee theft, vandalism, etc.), company policy violations, human resource matters, ethics violations, and other misconduct.
• When appropriate, and under the direction of company executives/board of directors, coordinates with federal and state law enforcement to pursue criminal prosecution of former employees.

Litigation

• Represents companies and individuals in both state and federal litigation.
• Has served as lead counsel on jury and bench trials and argued appellate matters before the Idaho Supreme Court and Court of Appeals.