Lawrence Ward
PEOPLE

Lawrence Ward

Partner
ward.lawrence@dorsey.com

Overview

ITAR, EAR, OFAC, CFIUS, NISPOM, FCPA…  AS AN INTERNATIONAL BUSINESS ATTORNEY, LARRY HELPS CLIENTS NAVIGATE THE COMPLEX ALPHABET SOUP OF U.S. NATIONAL SECURITY LAW AND INTERNATIONAL TRADE COMPLIANCE.

Larry serves as a partner in Dorsey’s National Security Law Group and is head of the firm's Seattle office. Larry helps government contractors, aerospace and defense, mining, technology, manufacturing, retail, service, hospitality, biotech and other companies involved in international trade understand and comply with various complicated U.S. regulatory schemes in a cost-effective manner so that they can avoid the monetary, criminal and other penalties and reputational damage faced when those regulations are violated. Larry advises clients ranging from small emerging companies to large public corporations and international professional associations. As a former appointed member of the U.S. State Department’s Defense Trade Advisory Group (DTAG), Larry has built important connections with U.S. Government and industry leaders, which further bolsters his ability to provide practical compliance insight to his clients.

Larry helps clients build and refine compliance programs, train employees, classify products for export purposes, apply for export licenses and classification requests from the U.S. Government and structure internal safeguards for dealing with classified federal government information. When something goes wrong, he helps companies internally investigate potential violations of the law and strategize how best to disclose violations to the U.S. Government. Larry also helps clients in building international relationships with various third parties by drafting and negotiating agency and distribution agreements, manufacturing agreements, intellectual property licenses, franchise agreements and other commercial contracts. Before those relationships are even built, he often helps clients craft due diligence programs and assists with vetting of potential foreign partners to ensure that the risks of violations of export control and international business ethics, anti-bribery and anti-corruption laws is low.

When the business stakes are highest and a client is involved in transactional activity, Larry provides export control due diligence. He also helps foreign buyers and U.S. targets navigate important regulatory issues associated with foreign investment in the United States when U.S. national security is implicated through the transaction.

Larry advises clients on compliance matters related to U.S. export controls and national security law and regularly represents clients before:

  • the U.S. Commerce Department on matters involving the Export Administration Regulations (EAR); 
  • the U.S. State Department on matters involving the International Traffic in Arms Regulations (ITAR); 
  • the U.S. Treasury Department on matters involving the economic sanctions administered by the Office of Foreign Assets Control (OFAC); 
  • the U.S. Energy Department and the Nuclear Regulatory Commission on matters involving energy and nuclear exports; 
  • the Committee on Foreign Investment in the United States (CFIUS) on regulatory issues associated with foreign investment in the United States; 
  • the U.S. Defense Department’s Defense Security Service (DSS) on compliance with the National Industrial Security Program Operating Manual (NISPOM) and with plans to mitigate foreign ownership, control and influence (FOCI); and 
  • the U.S. Justice Department and Securities and Exchange Commission on matters involving the Foreign Corrupt Practices Act (FCPA).

Education & Admissions

University of Notre Dame Law School (J.D., 2003), Dean’s List; Dean’s Award for Outstanding Academic Achievement in Trial Advocacy; Legislative Reform Editor, Journal of Legislation; Treasurer, Student Bar Association

University of Notre Dame (M.Ed., 2000), Highest Honors; Distinguished Portfolio

University of Notre Dame (B.A., 1998), Dean’s List, Class of 1998 Service Award

Admissions

  • Washington
  • California

Experience

Representative Matters

Export Control Matters

  • Prepared export control policies for various clients, ranging from an international engineering professional society to a Fortune 100 international manufacturing company
  • Prepared and delivered export control training programs for various clients, including a nuclear technology company, chemical company and multiple defense contractors
  • Led export control due diligence of a fabless communications semiconductor company’s acquisition of a leading provider of 4G wireless platform solutions
  • Developed FCPA compliance program and third-party agent questionnaire for an international fuel cell company 

Economic Sanctions Matters

  • Provided specialized OFAC economic sanctions and export control training to the Hong Kong operations of a major U.S. financial institution
  • Assisted a U.S. public company with investigating and voluntarily self-disclosing apparent violations of the OFAC Iranian sanctions by its Chinese affiliate and successfully negotiated a “cautionary letter” (i.e., no financial penalty) with OFAC in connection with the apparent violations
  • Worked with the Chinese office of a U.S. public company to provide tailored OFAC economic sanctions training to Chinese employees about the impact of those sanctions on foreign persons
  • Regularly assist underwriters in negotiating export control and economic sanctions representations, warranties, and covenants in various financing and related documents
  • Provided ongoing quarterly reports to the Board and management of one of the five largest U.S. financial institutions regarding the OFAC enforcement matter that our law firm handled on behalf of a company owned 49% by that financial institution
  • Provided training to a Norwegian bank regarding impact of U.S. export control and economic sanctions laws on the bank’s operations
  • Engaged by a Singaporean public company to respond to a subpoena from OFAC alleging that the company caused a major U.S. financial institution to repeatedly violate U.S. sanctions laws
  • Regularly work with a U.S. underwriter to help it understand U.S. export control and economic sanctions implications in certain deals financed by its EU and Asian operations
CFIUS Reviews
  • Represented a Chinese leading short-distance personal transportation vehicle maker based in Beijing in its acquisition of the world’s leading provider of personal electric transportation known for its two-wheeled, self-balancing, battery-powered electric vehicles in review by CFIUS
  • Represented a U.S. provider of cybersecurity solutions in its sale of various sensitive assets to a French owned defense contractor
  • Represented publicly held global provider of broadband communications network infrastructure products and related services in its acquisition by a foreign diversified manufacturing and services holding company
  • Represented Canadian company with U.S. holdings engaged in the mining and production of uranium in its acquisition by a Russian state-owned company in review and investigation by CFIUS
  • Represented Canadian company in its acquisition of two U.S. companies engaged in uranium mining and exploration in review by CFIUS
  • Represented Canadian utility infrastructure equipment and services company in its acquisition of a privately held water and wastewater utility services company in review by CFIUS
  • Represented U.S. space operations and ground network services provider in its acquisition by a Swedish state-owned space systems company in review and investigation by CFIUS and assisted the U.S. company in navigating on of the first of its kind mitigation agreements with the U.S. Defense Department for about a decade
  • Represented a U.S. enterprise data management provider in its acquisition by a Japanese holding conglomerate and negotiated a mitigation agreement with the U.S. Justice Department in connection with the acquisition
  • Represented a Chinese company in its acquisition of a U.S. aerospace manufacturing company and negotiated an extensive mitigation agreement with the U.S. Defense Department in connection with the acquisition
  • Represented Canadian fuel and petroleum distributor in its acquisition of U.S. fuel distributor with network of fuel service stations and convenience stores in review by CFIUS
  • Represented a Canada-based mining company on the regulatory aspects involved in the disposition of a 29% interest of stock that was held by a Chinese-controlled Canada-based company pursuant to an order by CFIUS

News & Resources

Articles

U.S. Piles on Array of New Sanctions Against Russian Military-Industrial and Financial Sectors
Biden Administration Adds Sanctions Against Foreign Financial Institutions Supporting Russia’s Military-Industrial Base
Fundamental Research & National Security: Recent Developments & New Issues
Executive Order 14105 on Outbound Investment in China and Proposed Rule
Outbound Investment Screening Becomes a Reality
DOJ Strike Force Allegations Highlight Diversion and Theft from U.S. Companies
U.S. Treasury Department Takes Action Against Russian Darkmarket Entity as Latest Government Move Against Cybercrime
Foreign-Owned U.S. Companies Must Soon Respond to Federal Survey
United States Imposes New 200% Tariffs on Russian Aluminum, Further Expands Sanctions on Russia, and Warns of New Third Country Sanctions
United States Continues Expansion of Export Control Sanctions on Chinese Companies
Congress, President Align on Powerful New U.S. Intellectual Property Protection Law
Year-End Omnibus Bill Includes First HSR Filing Fee Increases in More Than Twenty Years, Larger Agency Budgets, and New Foreign Subsidy Reporting Requirements
FCC Bars Imports of Telecommunications Equipment or Technology from Certain Chinese Producers
Biden Administration Restricts U.S. Exports of Advanced Computing and Semiconductor Manufacturing Equipment, Software, and Technology to China
Key Takeaways From President Biden’s Executive Order 14083 on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States (“CFIUS”)
CFIUS Annual Report - A Banner Year for Filings and Inquiries to Parties of Non-Notified Transactions
U.S. Customs and Border Protection Releases Importer Guidance for Uyghur Forced Labor Prevention Act Implementation
U.S. Treasury Department Clarifies Previous Prohibitions on New Investments in Russian Equities and on Export of Trust, Accounting and Management Consulting Services to Russia
U.S. Bars Accounting, Trust and Corporate Formation, and Management Consulting Services and Adds Export Restrictions to Russia
United States Bans Russian-Affiliated Ships from Entering Any U.S. Port
U.S. Government Sanctions Sberbank and Alfa Bank, Prohibits All New Investments in Russia, Imposes New Export Restrictions against Russian Civil Aviation & Ends PNTR Status for Russia and Belarus
U.S. Expands Russian Energy Sector Sanctions, Proposes Major Tariff Hikes on Nearly All Russian-Origin Goods & Imposes New Sanctions on Belarus
FinCEN Urges Financial Institutions to Guard Against Attempts to Evade Sanctions
United States Imposes More Sanctions to Block Russian Access to U.S. Banking System and U.S. Goods, Technology or Software
U.S. and Allied Countries Impose Sanctions Targeting Russian Financial Sector and Ukraine Separatist-Territories

News & Press Mentions

Chambers Global 2024 Recognizes Dorsey Partners and Practices
Alleged Russian crime boss sanctioned by Ukraine owns a major stake in US biotech firm
Chambers USA 2023 Recognizes 12 Dorsey Lawyers and Four Practices in Seattle
Chambers USA 2023 Recognizes Dorsey Lawyers and Practices
Dorsey Partner Larry Ward Discusses CFIUS Not Investigating Elon Musk's Twitter Purchase
Larry Ward Comments on Biden and G7 Stripping Russia's Trade Status
Larry Ward Comments on US Ban on Russian Oil
Larry Ward Comments on Russian Sanctions Affecting US Businesses
Dorsey Partner Larry Ward Comments on Efforts Underway to Extend CFIUS’s Reach in 2022
Larry Ward Discusses Cuban Sanctions
Dorsey Partner Larry Ward Comments on US Blacklisted Technology
Dorsey Partner Larry Ward Comments on Last-minute Foreign Policies
Dorsey Partner Larry Ward Looks Back and Ahead on CFIUS
How Washington's Most Equitable Workplaces have responded to 2020's challenges
How Washington's Most Equitable Workplaces create diverse recruiting pipelines
Dorsey’s Seattle Office Once Again Ranked in Most Equitable Workplaces
Dorsey Partner Larry Ward Comments on US Sanctions on Iran Banks
Dorsey Partner Larry Ward Comments on New Cuban Sanctions
Dorsey Partner Larry Ward Discusses New U.S. Restrictions on Cuba Activity
Dorsey Partner Larry Ward Comments on Trump's Cuban Sanctions
Dorsey Partner Larry Ward Discusses Nvidia's $40 Billion Purchase of Arm
Dorsey Names Lawrence Ward as Seattle Office Head
Dorsey Partner Larry Ward Comments on New US--Iran Sanctions
Dorsey Partner Larry Ward Discusses Trump's Iran Sanctions
Dorsey Partner Larry Ward Comments on US Huawei Ban

Select Presentations

  • Co-Presenter, “Cracking the CFIUS Code: Challenges to IP Rights in CFIUS Reviews,” New York City Bar Webinar, May 14, 2020
  • Presenter, “End-Use and End-User Due Diligence,” 11th Annual Pacific NW Export Control Conference, July 31, 2019
  • Presenter, “Import and Export Factors Impacting Northwest Businesses,” Pacific Northwest Defense Coalition Briefing, May 9, 2019
  • Co-Presenter, “Practical Issues in CFIUS and Export Controls,” Berkeley Center for Law & Technology, April 10, 2019
  • Presenter, “Structuring Your Classification Approach: Determining Jurisdiction,” PNDC’s Export Compliance Summit: EAR & ITAR, December 7-8, 2017
  • Presenter, “The Impact of Regulatory Changes on the M&A Market: Focus on Economic Sanctions, Export Control Laws, FCPA, and CFIUS,” 11th Annual M&A Seminar (The Seminar Group), November 1, 2017 
  • Presenter, Webinar “Introduction to the U.S. Export Administration Regulations (EAR),” PNDC Webinar, October 12, 2017
  • Presenter, “US Economic Sanctions and Russia, Doing Business in Today’s Russia: Practical Considerations for Minnesota Companies,” Sept. 26, 2017
  • Presenter, “Export Control Compliance in the Oil & Gas Industry,” Strafford Webinar (CLE), Sept. 12, 2017
  • Presenter, “Legal Due Diligence for Your Exporting Business,” Pacific Northwest Export Controls Conference (PNECC), Seattle University School of Law, July 27, 2017
  • Presenter, “International Trade Compliance,” 9th Annual Northwest Export Conference: Exporting and the New Administration – Compliance and Opportunities, Export Finance Assistance Center of Washington (EFACW), July 25, 2017
  • Co-presenter, “Section 734.13(b) of the EAR: How to Satisfy the ‘Deemed Export’ Rule, Foreign National Screening and Form I-129 Requirements amid Conflicting Foreign Privacy and Human Rights Laws,” ACI’s EAR Boot Camp on May 23-24, 2017
  • Co-presenter, “Labor & Employment Lawyers: What they should all know about U.S. Export Controls and Sanctions” Dorsey Video Training Program, April 28, 2017 
  • Presenter, “U.S. Economic Sanctions and Non-U.S. Companies,” BA-HR Programme: Anti-Corruption, Compliance and Trade Sanctions Seminar, January 19, 2017
  • Presenter, “Practical Tips For Responding to Export Control Concerns at all Stages of your Company’s Growth,” 2016 Export Controls Conference: Evolving Controls for a Changing World, Seattle, Washington, July 28, 2016
  • Co-presenter, “Structuring Your USML Classification Approach:  Understanding the “Order of Review” Post Reform, Determining ITAR Jurisdiction, and Submitting a Commodity Jurisdiction Request,” ACI’s 14th ITAR Boot Camp, Chicago, Illinois, May 25, 2016
  • Co-presenter, “U.S. Economic Sanctions Programs and Recent Changes Impacting What Banks Can Do in Cuba and Iran,” Dorsey Bank Counsel Roundtable, April 27, 2016
  • Presenter, “Overview of U.S. Economic Sanctions and their Impact on Exporters,” Pacific Northwest Defense Coalition (PNDC) – Defense Export Compliance & Opportunities Conference, Seattle, Washington, April 21, 2016
  • Presenter, “Important Developments on US Iranian Economic Sanctions,” ABA Sanctions Year in Review, Washington, DC, February 2, 2016
  • Presenter, “Enforcement Cases and What to do if Something Has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, December 9-10, 2015
  • Co-presenter, “International Traffic in Arms Regulations (ITAR) Update,” PNDC Lunch & Learn, Seattle, Washington, September 30, 2015
  • Presenter, “Export Violations in the Post-ECR Environment,” 2015 Export Controls Conference, Seattle, Washington, July 29-30, 2015
  • Co-presenter, “Navigating Ukraine-Related Sanctions: Meeting the Latest U.S. and E.U. Sanctions,”  Strafford CLE, June 9, 2015
  • Presenter, “U.S. National Security Laws and Their Impact on Classified Contractors,” DSS CI & FBI Strategic Counterintelligence Partnership with Defense Industrial Base - 2nd Annual Conference, Anchorage, Alaska, May 7, 2015
  • Co-presenter, “When and How to Submit a CJ Instead of Conducting a Self-Determination: How to Prepare the Request and What to Do after Receiving a DDTC and DTSA Determination,” ACI’s 13th ITAR Boot Camp, San Diego, California, February 24-25, 2015
  • Presenter, “Russia/Ukraine-related sanctions,” ABA Sanctions YIR Event, Washington, DC, January 29, 2015
  • Presenter, “Impact of U.S. Export Control Laws on Immigration Filings,” Dorsey Breakfast Briefing, January 27, 2015
  • Presenter, “2014 Enforcement Matters and What to do When Something Has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, January 8, 2015
  • Panelist, “What BIS and DDTC Expect from Your Technology Control Plan: How to Incorporate and Implement New IT Management, Security and Training Procedures that will Impress the Agencies,” American Conference Institute’s 8th Forum on International Technology Transfers & Deemed Export Compliance, San Francisco, California, September 2014
  • Co-panelist, “OFAC Ukraine-Related Sanctions: Overcoming Compliance Challenges, Meeting Evolving U.S. and EU Sanctions,” Strafford CLE, September 2014
  • Presenter, “Internal Investigations and Voluntary Self-Disclosures,” Microsoft Export Controls 2014 Conference, Redmond, Washington, July 10, 2014
  • Co-presenter, “Ensuring Your Company’s Success Through Compliance with the U.S. Foreign Corrupt Practices Act,” PNDC ITAR Summit, Portland, Oregon, January 30, 2014
  • Presenter, “Recent Enforcement Cases and What to Do if Something has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, January 30, 2014
  • Co-presenter, “Establishing & Maintaining an Effective Export Controls Compliance Program,” PNDC ITAR Summit, Portland, Oregon, January 29, 2014
  • Presenter, “2013 U.S Export Controls Year in Review,” ABA Section of Internationals Law, Washington, DC, January 2014
  • Panel Moderator, “Stay Private or Take Our A&D Company Public?” Orange County Aerospace and Defense Forum, Costa Mesa, California, November 2013
  • Panelist, “Export Control Reform and Industry,” ICE Seattle Export Control Seminar, October 2013
  • Presenter, “An Overview of Export Controls under the U.S. Department of Commerce,” ICE Seattle Export Control Seminar, October 2013
  • Presenter, “Recent FCPA Developments and Conducting Internal Investigations,” WSBA International Law Section CLE, Seattle, Washington, September 2013
  • Panel Moderator, “Is Your A&D Company Part of the $500B Yearly CYBER Loss?” Orange County Aerospace and Defense Forum, Costa Mesa, California, August 2013
  • Presenter, “Recent Developments with CFIUS,” Dorsey U CLE Program, July 2013
  • Presenter, “Nuts and Bolts of Export Controls: Dealing with the Regulations,” Pacific Northwest Defense Coalition and U.S. Commercial Service, Portland Oregon, January 2013
  • Presenter, “Overview of the Foreign Corrupt Practices Act,” Pacific Northwest Defense Coalition and U.S. Commercial Service, Portland Oregon, January 2013
  • Presenter, “How U.S. Export Control and Related Laws and Regulations May Change during the Next Four Years,” Orange County Aerospace and Defense Forum, Costa Mesa, California, December 2012
  • Presenter, “The Impact of Deemed Exports in the University and Research Institute Setting,” Export Council of Oregon and U.S. Commercial Service, Portland, Oregon, November 2011 and December 2012
  • Presenter, “Fundamentals of U.S. Export Control Laws,” WSBA International Law Section CLE, Seattle, Washington, September 2012
  • Presenter, “U.S. Export Controls,” Montana World Trade Center, Bozeman, Montana, May 2012
  • Presenter, “Overview of the U.S. Foreign Corrupt Practices Act,” U.S. Commercial Service and Pacific Northwest Defense Coalition, Portland, Oregon, January 2012
  • Presenter, "Legal Considerations for International Business," Montana World Trade Center ExporTech, Missoula, Montana, April 2011
  • Presenter, "Basic Considerations for Selling and Sourcing in International Agreements," International Trade Alliance New-to-Export Seminar, Seattle, Washington and Tukwila, Washington, March, August and September 2011
  • Presenter, “Foreign Investments and Acquisitions in the United States: Dealing with CFIUS,” Dorsey U CLE Program, February 2011

Industries & Practices

Government Solutions & Investigations
Government Contracts Counseling & Litigation
Environmental, Social, Governance (ESG)
  • Antitrust & Competition Law
  • Aviation
  • Banking & Financial Institutions
  • China
  • Development & Infrastructure
  • Electric Power
  • Energy & Natural Resources
  • Environmental, Social, Governance (ESG)
  • FinTech
  • Food, Beverage & Agribusiness
  • Government Contracts Counseling & Litigation
  • Government Solutions & Investigations
  • Healthcare & Life Sciences
  • Intellectual Property
  • International Trade
  • Mergers & Acquisitions
  • Mining
  • National Security Law
  • Oil & Gas
  • Sustainability
  • Technology
  • Technology Commerce

Professional & Civic

Professional Achievements

  • Defense Trade Advisory Group (DTAG) for the U.S. Department of State, Former Appointed Member
  • Export Controls and Economic Sanctions Committee of the ABA Section of International Law, Steering Group Member and “Year in Review” Co-Editor
  • Washington District Export Council, Member
  • Pacific Northwest Defense Coalition (PNDC), Member

Community Involvement

  • Treehouse, Board Member, 2013 to Present
  • Communities Rise (fka Wayfind), Board Member, 2012 to 2018
  • Washington State Bar Association, International Practice Section, Member
  • St. Joseph School, Former School Commission Member

Accolades

Chambers USA 2023

  • Named one of “America’s Leading Business Lawyers” by Chambers USA ( International Trade: CFIUS Experts), 2023

Pro Bono 50 Hours 2022    Contributed 50+ Pro Bono Hours in 2021

  • Contributed more than 50 Challenge pro bono hours, 2021-2022
  • Dorsey & Whitney – Scales of Justice Team Award (The World Ventilator Foundation), 2021
  • Dorsey & Whitney – Scales of Justice Team Award (Promise of Justice Initiative’s Unanimous Juries Project), 2022
  • Appointed to the Defense Trade Advisory Group (DTAG)
  • Recognized as a "40 Under 40" honoree by the Puget Sound Business Journal, 2013
  • Listed as a “Rising Star” by Washington Super Lawyers, 2013-2015
Lawrence Ward