Clients say Mr. Carnegie’s “knowledge of US sanctions is excellent, as are his relationships with OFAC personnel. He has a friendly manner that puts our businesses at ease and he is able to offer practical and operational solutions to their issues.”

Chambers USA 2016

Les P. Carnegie

Washington, D.C.
  • 555 Eleventh Street, NW
  • Suite 1000
  • Washington, D.C. 20004-1304
  • USA

Les Carnegie is a partner in the Washington, D.C. office, Co-chair of the Export Controls, Economic Sanctions & Customs Practice, and member of the firm's Finance Committee. He has extensive experience in a wide variety of international trade and national security matters.

Mr. Carnegie’s practice focuses on legal, policy, and enforcement issues arising under US export controls, trade and economic sanctions, antiboycott restrictions, national security reviews of foreign investments in the United States, and compliance with the Foreign Corrupt Practices Act (FCPA). With a particular focus on leading complex internal investigations, preparing disclosures to the US government, and developing compliance programs, he has specialized expertise in the aerospace, defense, life sciences, energy, financial, and high technology industries.

Mr. Carnegie has been recognized by Chambers USA 2016-2017 and by The Legal 500 US 2014-2016 for his international trade practice and was a recommended lawyer in 2014 in white collar criminal defense. He is a frequent speaker on issues relating to US export controls and economic sanctions and is a member of the Steering Group for the Export Controls and Economic Sanctions Committee of the American Bar Association Section of International Law.

Mr. Carnegie represents and counsels clients regarding various legal regimes that govern international trade, technology transfers, investment, and cross-border business activities, including: 

  • Trade and economic sanctions administered by the Treasury Department's Office of Foreign Assets Control (OFAC) 
  • Defense trade controls under the International Traffic in Arms Regulations (ITAR) administered by the US Department of State (DDTC), and related import provisions administered by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) 
  • Dual-use, commercial, and defense-related export controls under the Export Administration Regulations (EAR), the Foreign Trade Regulations (FTR), and antiboycott regulations administered by the US Department of Commerce 
  • National security reviews of foreign investments in the US under the Exon-Florio amendments, administered by the Committee on Foreign Investment in the United States (CFIUS) 
  • The US Foreign Corrupt Practices Act (FCPA), enforced by the US Department of Justice and the US Securities and Exchange Commission

Mr. Carnegie has extensive experience in the following areas: 

  • Organizing and conducting internal investigations, preparing voluntary disclosures to the US government, and negotiating resolutions with the relevant US agencies 
  • Responding to government investigations and enforcement actions 
  • Developing, implementing, and enhancing US foreign trade control compliance programs and strategies as well as preparing and delivering US trade compliance training 
  • Organizing international trade due diligence in connection with contemplated mergers, acquisitions, joint ventures, or other business activities, including advising clients on compliance with US sanctions in the financing context 
  • Securing government approvals, commodity jurisdiction rulings and advisory opinions from the relevant US agencies, including the Commerce Department’s Bureau of Industry and Security (BIS), DDTC, and OFAC  
  • Advising companies, in and outside the United States, on the process of securing national security clearance from CFIUS, and related export control reviews

Prior to entering private practice, Mr. Carnegie clerked for Judge Gerald B. Tjoflat of the US Court of Appeals for the Eleventh Circuit (1999-2000).

Thought Leadership 
  • Co-Author, “Expanded Russia, Iran, and North Korea Sanctions: Top 10 Takeaways,” Client Alert, August 2, 2017 
  • Co-Author, “Among Final Actions, Obama Administration Suspends Core of US Sanctions Against Sudan,” Client Alert, January 30, 2017  
  • Speaker, “Mitigating Facilitation Risks: Top 5 Red Flags that Could Indicate a Facilitation Issue,” ACI's 7th Annual New York Forum on Economic Sanctions, December 7, 2016
  • Speaker, "Recent Developments in U.S. Sanctions," 2016 Business Law and International Law & Practice Sections Joint Annual Meeting, February 19, 2016
  • Co-author, “Iran Nuclear Agreement Negotiation Advances Trigger Limited Easing of US and EU Sanctions,” Client Alert, January 28, 2014 
  • Co-author, “CFIUS 2012 Annual Report Reveals Increase in Chinese Filings and Notice Withdrawals,” Client Alert, January 21, 2014 
  • Co-author on a series of Latham Client Alerts pertaining to US and EU Sanctions on Russia, dated March 7, 2014, March 18, 2014, March 21, 2014, April 29, 2014, July 18, 2014, July 30, 2014, July 31, 2014 
  • “US Export Controls and Economic Sanctions – What Companies Need to Know,” Q&A, July 16, 2013 
  • Co-author, “Key Elements of an Effective US Foreign Trade Controls Compliance Program,” Coping with US Export Controls (2006-2009)

Mr. Carnegie’s representative matters include the representation of: 

  • Leading aerospace and defense companies in connection with compliance with US export controls and US sanctions, including voluntary disclosures to the State, Commerce, and Treasury Departments 
  • Leading electric and nuclear energy companies, oil exploration and production companies, as well as oil services companies with compliance on US export controls, US sanctions, and designing compliance programs, as well as voluntary disclosures to the Treasury and Commerce Departments 
  • Leading high-technology companies, including Fuse Deposition Modelling 3-D printing company, on compliance with US foreign trade controls 
  • A number of medical device and pharmaceutical companies, including Genzyme Corporation, in helping to secure government licensing for sales of humanitarian products to countries subject to US economic and trade sanctions 
  • Leading not-for-profit organizations, including CARE USA and Mercy Corps, in connection with compliance with US export controls and US sanctions, including securing export licensing and OFAC authorization 
  • Leading several US and non-US companies in successful representation before CFIUS
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