Photograph of David (Dj) Wolff

David (Dj) Wolff

Partner; Attorney at Law


David (Dj) Wolff is a partner and attorney at law in the firm's Washington, D.C. and London offices and a director with C&M International, the firm's trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj’s recent significant matters include:

Economic Sanctions Counselling

  • Secured successful closure of OFAC subpoena without penalty relating to a review of U.S. service provider’s compliance with Russia-related “sectoral” sanctions.
  • Conducted week-long intensive sanctions training for more than 300 bank compliance officers in four countries on three continents over the course of three months. 
  • Implemented sanctions-screening system for U.S. manufacturer’s global operations, including designing the internal policies and procedures, training the internal compliance teams, and managing the review, escalation, and disposition of potential matches. 
  • Seconded to EU based financial institution’s branch office in Dubai to serve as in-house sanctions counsel providing daily guidance on sanctions-related compliance and investigation matters.
  • Represented, including through direction of local counsel across three jurisdictions, a multinational manufacturer in response to a criminal inquiry from the Russian customs authority related to exports to Russia.
  • Served, in collaboration with a U.K. colleague, as expert witnesses related to U.S. and U.K./EU economic sanctions, in litigation in Scotland, on behalf of a Scottish firm, related to the largest professional negligence claim ever filed in Scotland.
  • Seconded to federally-regulated U.S. financial institution as its Global Economic Sanctions Compliance Leader responsible for overseeing a worldwide economic sanctions compliance program and a team of experts covering numerous third country subsidiaries and millions of annual transactions and customers.
  • Led internal investigation for a U.S. manufacturer of activity undertaken by a newly acquired subsidiary in potential violations of U.S. and EU economic sanctions and export controls involving a team of lawyers in the U.S., United Kingdom, and Brussels.
  • Collaborated with U.S. and EU data privacy colleagues to represent a non-U.S. subsidiary of a U.S. financial institution in a petition to the French Data Privacy authority for authorization to conduct screening for sanctions compliance against certain types of personal identifying information.
  • Represented U.S. manufacturer of equipment used in refineries and downstream oil and gas facilities in reviewing all potential transactions for compliance with U.S. and EU blocking and sectoral sanctions on Russia.
  • Represented a multinational publishing company with respect to the scope of the exemptions and authorizations related to informational material and publishing services for countries subject to U.S. embargo.
  • Assisted in the internal review and development of a prospective trade compliance plan for a multinational service provider’s back-office support for its non-U.S. customers potentially doing business in sanctioned countries.
  • Conducted due diligence on a potential target company’s compliance with U.S. economic sanctions and export controls on behalf of a U.S. private equity firm in a successful $1.4 billion acquisition.

Export Controls & Antiboycott

  • Represented a U.S. manufacturer in negotiations with the Bureau of Industry and Security (BIS) and Customs and Border Protection (CBP) to secure release of oil and gas equipment improperly seized before export to Russia.
  • Secured commodity jurisdiction determination from the Department of Defense Trade Controls (DDTC) for a U.S. manufacturer to confirm its product was not subject to the International Traffic in Arms Regulations (ITAR).
  • Prepared a series of commodity classification requests (CCATS) for a U.S. manufacturer.
  • Represented a U.S. financial institution in an internal investigation and voluntary disclosure to the U.S. Commerce Department of potential violations of the U.S. antiboycott regulations.
  • Prepared quarterly and annual antiboycott reports for the Commerce Department and the Treasury Department for U.S. manufacturer.

International Trade Policy and Multilateral Institutions

  • Represented a wide range of U.S. associations in developing and advancing public-private initiatives in the Asia-Pacific Economic Cooperation Forum (APEC), including in-person meetings in China, Indonesia, Papua New Guinea, Peru, the Philippines, and Vietnam.
  • Represented a U.S. trade association in negotiations with the European Commission regarding market access and regulatory cooperation aspects of the potential Trans-Atlantic Trade and Investment Partnership (TTIP).
  • Represented a trade association during negotiating sessions of the World Intellectual Property Organization (WIPO) Intergovernmental Committee on Intellectual Property and Genetic Resources, Traditional Knowledge and Folklore.
  • Coordinated a “roadshow” and in-person meetings for a U.S. trade association in countries party to the Trans-Pacific Partnership (TPP) during the TPP’s negotiations.

Pro Bono

  • Represented a non-profit in securing the first-ever public exemption granted by the United Nations Security Council’s 1718 Committee from North Korea related sanctions to a non-UN affiliated body.
  • Secured OFAC and BIS licenses for U.S. non-profit to undertake multi-drug resistant tuberculosis treatment involving U.S. persons and U.S. products in North Korea.
  • Prepared training on compliance with U.S. sanctions, export controls, and anti-corruption legislation for a U.S. non-profit providing in-person tuberculosis and AIDS treatment around the world.
  • Argued in front of the D.C. Circuit as amicus appointed by the Court in support of a D.C. inmate’s suit for damages against U.S. Parole Commissioners.
  • Represented DC inmate in Innocence Project motions and subsequent parole board hearings, ultimately resulting in the client’s successful release on parole.
  • Coordinated C&M’s weekly tutoring program for the Thurgood Marshall Academy, a charter high school with a pre-law focus based in Anacostia.

Education

  • Stanford Law School, J.D.
  • London School of Economics and Political Science (LSE), M.Sc., merit
  • Dartmouth College, B.A., summa cum laude

Affiliations

Admitted to practice: District of Columbia, New York, the Court of International Trade, the Federal Circuit, and the U.S. Court of Appeals for the D.C. Circuit

View More

How Russia Sanctions Helped Kill 15-Minute Delivery In New York The Washington Post (June 2, 2022)
Press Coverage
Chambers USA 2022 Ranks 70 Crowell & Moring Lawyers and 37 Practice Areas Among Best in U.S. (June 1, 2022)
Firm News / Announcement
"Russia Sanctions/Export Highlights [As of April 28, 2022]," Crowell & Moring’s International Trade Law Blog (April 28, 2022). Authors: Caroline Brown, Carlton Greene, Jeffrey L. Snyder, Anand Sithian, Laurel Saito, and Rachel Schumacher.
Publication
Continuing To Do Business In Russia Carries Risks, But So Does Decoupling, Lawyers Say Export Compliance Daily (April 25, 2022)
Press Coverage
"Ukraine Crisis Webinar," Crowell & Moring Webinar, 2022. (April 21, 2022). Speakers: Vass Akritidis, Bryan Brewer, Caroline Brown, Carlton Greene, Andrew Martin, John Murino, Nicole Simonian, Rob Sneckenberg, Scott Winkelman, Dj Wolff, Alex Urbelis, and Laura Baker
Speech/Presentation
"What Designating Russia as a State Sponsor of Terrorism Would Mean," International Dispute Resolution Alert (April 20, 2022). Contacts: Leslie Castello, John L. Murino, David (Dj) Wolff
Client Alert / Newsletter
"Global Trade Talks: Russia and Ukraine - Expecting the Unexpected with Dj Wolff and Carlton Greene," Podcast: Global Trade Talks (April 14, 2022). Contacts: Robert Holleyman, Nicole Janigian Simonian, Carlton Greene, David (Dj) Wolff
Client Alert / Newsletter
"Update: Expanded U.S. Ban on Russian Imports and Russia’s Removal from Permanent Normal Trade Relations Status," Crowell & Moring’s International Trade Law (March 29, 2022). Authors: John B. Brew, David (Dj) Wolff, Maria Vanikiotis, Frances P. Hadfield, Anand Sithian and Chandler S. Leonard.
Publication
"Government Contracts M&A Series – National Security Issues," Crowell & Moring Webinar, 2022. (March 22, 2022). Speakers: Adelicia R. Cliffe, Jonathan M. Baker, Dj Wolff, and Stephanie L. Crawford.
Speech/Presentation
New York Playbook – March 16, 2022 POLITICO (March 16, 2022)
Press Coverage

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