Kara Bombach assists companies in numerous industries to lawfully export goods, technology and services around the globe. Her international trade practice focuses on compliance with anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals. Ms. Bombach regularly represents clients in foreign trade-related matters before U.S. government agencies, including the Departments of Commerce, State, Treasury and Defense. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations.
National and multi-national companies (includingFortune5) have engaged Kara to assist in establishing and maintaining effective trade compliance programs critical to efficient and productive international business operations. Among other things, she regularly counsels clients in designing and implementing global anti-corruption and trade compliance programs, including complex and high impact issues such as compliance assessments and government investigations. She has significant experience advising clients on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anticorruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.
In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.
Kara actively writes and presents on export, sanctions and anti-corruption topics, and has been recognized byWashington, DC Super Lawyersfor her involvement in such areas.
Kara currently serves as Outside General Counsel to ALESA (American League for Export and Security Assistance), whose members include major multinational aerospace and defense companies. Through her involvement with ALESA, Ms. Bombach has gained a deep understanding and working knowledge of the issues faced by the aerospace and defense industries.
Areas of Concentration
•Export controls and economic sanctions
•International trade compliance
•Regulatory due diligence
Awards & Recognition
•Listed,Super Lawyersmagazine,Washington, D.C. Super Lawyers, Rising Star, 2013
•Intern, United Nations International Atomic Energy Agency Headquarters, Vienna, Austria, 1995-1996
Articles, Publications, & Lectures
•Co-Author, U.S. Government Announces Significant Changes to Export Controls on Spacecraft and Satellites ,GT Alert, June 2, 2014
•Co-Author, U.S. Sanctions Individuals in Central African Republic ,GT Alert, May 21, 2014
•Author, What Does Anti-Corruption Due Diligence Really Mean? Corporate Compliance Insights, March 31, 2014
•Co-Author, U.S. and EU Respond to Ukraine Crisis with Sanctions ,GT Alert, March 27, 2014
•Quoted, Streamlined Trade Data System May Speed Enforcement ,Law360, February 25, 2014 (Subscription)
•Author, UK Bribery Act Enforcement Is On The Horizon,Law360, February 12, 2013
•Quoted, Going Global: Building Your Team ,The Wall Street Journal, November 8, 2011
•Co-Author, Justice Department Beefs Up Foreign Corruption Act Enforcement ,National Defense Magazine, February 2011
•Committee Editor, ABA Export Controls and Economic Sanctions, International Legal Developments in Review: 2010, 45Int'l Law.19 (2011).
•Co-Author, The Long Arm Of the UK Bribery Act ,National Defense Magazine, December 2010
•Co-Author, Contractors Must Take Ownership of Export Control Compliance ,National Defense Magazine, September 2010
•Co-Author, Informing DOD Suppliers Of Export Control Obligations ?Law360, June 30, 2010
•Co-Author, Deals Can Be Derailed by Security Concerns ,National Defense Magazine, August 2009
•Co-Author, ITT Penalties: Does the Punishment Fit the Crime ?National Defense Magazine, June 2007
•Co-Author, Anti-Bribery Enforcement On the Increase Overseas ,National Defense Magazine, August 2006
•Panelist, The Importance of FCPA and Anti-Corruption Risk Assessments, Association of Corporate Counsel Webcast, June 3, 2014
•Speaker, Global impact of US anti-corruption measures, Corporate Compliance with Corruption Laws, Association of Corporate Counsel (Israel), Tel Aviv, Israel, April 30, 2014
•Speaker, U.S. and Israeli Export Control Regulation Seminar, Tel Aviv & Central Israel Chamber of Commerce, Tel Aviv, Israel, April 29, 2014
•Presenter, Resolving Complex Classification Issues, American Conference Institute ITAR Compliance Forum, Washington, D.C., July 15, 2011
•Presenter, CHINA - Tailoring an Export Compliance Program for Your Operations in China: Do's and Don'ts for Balancing US and Local Restrictions, American Conference Institute, Washington, D.C., May 24-25, 2011
•Guest Lecturer, Weapons Industry, Industrial College of the Armed Forces, April 20, 2011
•Panelist, FCPA: Practical Perspectives on Compliance American Bar Association, Washington, D.C., April 11, 2011
•Presenter, Don't Let Export Control Violations Ruin Your Deal, Association for Corporate Growth, McLean, VA, April 20, 2010
•Guest Lecturer, Weapons Industry, Industrial College of the Armed Forces, April 12, 2010
•Presenter, Defining and Controlling Technical Data, American Conference Institute's, ITAR Boot Camp, Orlando, FL, October 20, 2009
•Presenter, Using ITAR Licensing Exemptions, American Conference Institute ITAR Boot Camp, Orlando, FL, October 20, 2009
•Panelist, Overseeing Business Overseas, Association of Corporate Counsel Northeast Chapter and Greenberg Traurig, Boston, MA, October 17, 2007
Associated News & Events
04.29.13 13 Greenberg Traurig Attorneys Listed in 2013 Washington, D.C. Super Lawyers
03.09.10 Greenberg Traurig Names New Shareholders in Washington, D.C.
01.01.10 Greenberg Traurig Names New Shareholders and Of Counsel
03.31.14 What Does Anti-Corruption Due Diligence Really Mean?
02.12.13 UK Bribery Act Enforcement is on the Horizon
06.02.14 U.S. Government Announces Significant Changes to Export Controls on Spacecraft and Satellites
05.21.14 U.S. Sanctions Individuals in Central African Republic
03.27.14 U.S. and EU Respond to Ukraine Crisis with Sanctions
02.11.13 The UK's Bribery Act - Enforcement on the Horizon?
11.16.12 DOJ and SEC Release New Guidance on FCPA: More Clarity but Few Bright Lines
08.27.12 U.S. Government Permits New Investment in Burma
08.14.12 Foreign Subsidiaries Now Must Comply with U.S. Sanctions Against Iran
08.08.12 Iran Sanctions Liability May Reach Non-U.S. Subsidiaries in Near Future
10.17.11 Food Exports Allowed to Iran and Sudan Under New General License
04.21.11 Proposed Amendment to ITAR Clarifies Definition of 'Defense Services'