Venezuelan Oil Sanctions: Structuring Energy Transactions Under OFAC General Licenses

Mr. DuCharme chairs Bracewell’s national Government Enforcement & Investigations (GEI) practice and provides personal attention, a formidable presence and highly responsive counsel to clients facing government scrutiny. He works directly with companies and individuals to navigate complex enforcement challenges, ensuring that every matter receives his focused involvement and strategic guidance. Known for his accessibility and hands-on approach, Mr. DuCharme partners closely with clients to address urgent needs and leverage his experience serving in senior leadership positions at the Department of Justice to deliver practical, effective solutions when the stakes are highest. He represents companies and individuals in the investigation and defense of a variety of federal and state regulatory, criminal and civil matters, including matters relating to healthcare, cryptocurrency enforcement, national security, cross border regulation, cyber security and data breach response, Foreign Corrupt Practices Act (FCPA) diligence and litigation, Foreign Agents Registration Act (FARA), export controls, sanctions compliance and anti-money laundering.

Mr. Racco advises clients on a wide range of international trade regulations, including sanctions and export controls under the Export Administration Regulations, Foreign Trade Regulations, International Traffic in Arms Regulations), and Office of Foreign Assets Control regulations. He also routinely counsels clients on the Committee on Foreign Investment in the United States (CFIUS) regulations, anti-boycott laws, Withhold Release Orders, and anti-corruption laws including the Foreign Corrupt Practices Act. Mr. Racco provides clients with a variety of trade compliance services, such as: transaction-related due diligence; counseling on, and the preparation of, filings to CFIUS; determining the export classifications of products; advising on and preparing export license applications; providing advice and counsel on a wide range of sanctions questions; complying with, and challenging WROs and findings of forced labor by Customs and Border Protection; delivering compliance training; and helping clients design and implement tailored international trade compliance policies and procedures. In addition, he has conducted hundreds of internal investigations related to potential violations of international trade compliance regulations and has extensive experience drafting voluntary disclosures to relevant agencies.