Kirsten Hoffstedt Keefe

Practices

• International Trade & Customs
• International

Professional Experience

Kirsten is senior counsel in the International Trade & Customs practice group. Kirsten's practice covers a wide range of issues and regulations related to the cross-border movement of goods, technology and people.

Kirsten's practice focuses on compliance and enforcement matters related to U.S. export control, economic sanctions, antiboycott, anti-bribery and customs laws and regulations. Her broad experience includes issues related to the Export Administration Regulations (EAR), administered by the U.S. Department of Commerce's Bureau of Industry and Security (BIS); the International Traffic in Arms Regulations (ITAR), administered by the U.S. Department of State's Directorate of Defense Trade Controls (DDTC); sanctions laws administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC); customs laws administered by U.S. Customs and Border Protection (CBP). A seasoned trade professional and advocate, Kirsten brings a global perspective and practical solutions to the complex issues faced by client companies and individuals.

Kirsten has prepared significant compliance programs in the areas of import of export control - programs that are tailored to each company's structure, industry and risks. She has assisted clients with implementation, auditing and training regarding both the legal requirements and internal policies and procedures. Kirsten regularly provides guidance related to the classification of goods and technology under the ITAR, EAR and HTS, and assists with any licensing requirements. Where non-compliance is discovered, Kirsten works with clients on a strategic response to mitigate risk and exposure - investigating past practices, designing remedial procedures, preparing voluntary disclosures and negotiating with government officials, as needed.

Her representative matters feature technical and classification experience in a broad range of industries, including aerospace, avionics, oil and gas, chemical processing, software, telecommunications, electronics, auto parts, industrial process equipment, chemicals and coatings, consumer goods, agricultural goods, prepared foods, textiles, protective equipment, and defense services.

In addition to import and export compliance and enforcement, Kirsten regularly conducts due diligence on trade and anti-bribery issues, and Exon-Florio/ Committee on Foreign Investment in the United States (CFIUS) reviews of mergers.

During her academic career, Kirsten served as a law clerk with a French firm in Paris and was awarded a Rotary International Ambassadorial Scholarship for a year of study at the Sorbonne. Prior to attending law school, Kirsten worked for an agency of the Korean government in Chicago to facilitate trade and foreign direct investment between Midwestern companies and Korea.

Kirsten is also engaged in many firmwide activities, including participation in the Diversity & Inclusion Initiative and Women's Initiative. Kirsten is admitted to practice in the District of Columbia and the state of Maryland.

Education

• Georgetown University Law Center, J.D., 2003
• Luther College, B.A., 1995, summa cum laude

• Export Controls and Economic Sanctions
• Prepare customized policies and procedures for compliance with U.S. export control and economic sanctions laws, identifying overlap with global export regulations.
• Conduct internal audits and investigations of export practices, and prepare remedial measures.
• Prepare voluntary disclosures to OFAC, BIS and DDTC in furtherance of clients’ risk management strategy.
• Analyze compliance issues related to exports and reexports to sanctioned countries, including under heightened sanctions against Iran and Syria
• Determine export classification and licensing requirements for goods, technology, and software.
• Prepare successful Commodity Jurisdiction requests for next-generation products.
• Conduct due diligence regarding potential acquisitions, develop post-closing strategy regarding treatment of past violations, negotiate with government agencies, and design prospective compliance measures.
• Conduct in-person and web-based training for company leadership and personnel regarding export control, sanctions, antiboycott, and AES filing requirements.
• Analyze potential antiboycott requests and provide advice regarding reporting requirements.
• Represent companies in investigations and settlement negotiations with export control and sanctions agencies.
  
  
• Customs
• Prepare customized policies and procedures for compliance with U.S. Customs requirements
• Determine import classification and related Customs requirements for imported goods, often resulting in import duty savings
• Conduct internal audits and investigations of import practices, and prepare remedial measures.
• Prepare prior disclosures to CBP in furtherance of clients’ risk management strategy.
• Conduct in-person and web-based training for company leadership and personnel regarding Customs and free trade agreement (e.g., NAFTA) requirements.
• Represent companies in investigations and settlement negotiations with CBP.
  
  
• FCPA
• Analyze FCPA and other anti-bribery risks and provide advice regarding policies, procedures and third-party due diligence and certifications.
• Conduct due diligence regarding FCPA/anti-bribery exposure, and prepare remedial measures.
  
  
• Other Trade Issues
• Conduct CFIUS reviews of potential mergers and acquisitions.

• French