Mahmoud B. (Mac) Fadlallah focuses his practice on global investigations and compliance, including in the areas of export controls, economic sanctions, anticorruption and antibribery. Based in Dubai, his practice emphasizes on the application of U.S. law to non-U.S. entities and operations. He advises public and private sector clients in the aerospace and defense, satellite, logistics and freight forwarding, communications and technology, oil and gas, health care, medical device, industrial, chemical and other industries.
Practice & Background
Mr. Fadlallah regularly advises clients on compliance with the Foreign Corrupt Practices Act (FCPA), the State Department’s International Traffic in Arms Regulations (ITAR), the Commerce Department’s Export Administration Regulations (EAR) and the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctions.
Mr. Fadlallah also counsels clients on compliance with regulations administered by the Drug Enforcement Agency (DEA), including responding to DEA audits, requests and potential enforcement actions. He has also engaged in pro bono representation of abused immigrant women seeking relief under the Violence Against Women Act.
Mr. Fadlallah earned his J.D. in 2008 from the University of Minnesota, where he completed a concentration in international human rights law and served on the editorial board of the Minnesota Law Review.
Mr. Fadlallah’s representative matters include:
- conducting internal compliance investigations of possible FCPA, ITAR, EAR or OFAC regulations and related company policies, and facilitating compliance audits
- developing and implementing compliance policies and procedures, with an emphasis on non-U.S. entities
- drafting voluntary disclosures of U.S. export controls and sanctions violations to competent U.S. government agencies and managing subsequent interface with the government in the context of settlement negotiations
- responding to subpoenas issued by the U.S. government related to anticorruption, export control or sanctions matters
- implementing and managing IT tools to facilitate international trade compliance, including automated export control modules and denied party screening solutions
- counseling clients on matters related to encryption controls, including obtaining encryption registrations and preparing encryption classification requests
- advising clients making export control jurisdictional determinations and, where appropriate, self-classifying their products, technology and software under the U.S. Munitions List or the Commerce Control List
- securing significant and unprecedented BIS, ITAR and OFAC licenses (including ITAR Technical Assistance Agreements or Manufacturing License Agreements) as well as ITAR registration applications for manufacturers, exporters and brokers of defense articles and services
- preparing general and topic-specific export controls and sanctions compliance trainings, manuals and memoranda.