AndrewAstuno

Консультант Вашингтон, округ Колумбия

Эндрю Астуно

Andrew Astuno is Counsel at Seiden Law, where he advises corporations, investors, and sovereign entities on U.S. economic sanctions, export controls, CFIUS investment screening, anti-corruption, and lobbying regulation. He represents clients before OFAC, BIS, CBP, and CFIUS at every stage of a matter, from structuring transactions to defending enforcement. Clients and referring counsel retain him when a regulatory problem requires someone who has worked inside the government and litigated on both sides of the table at leading international firms, drawing on prior service at the U.S. Department of the Treasury and subsequent experience at Clifford Chance and Stroock & Stroock & Lavan.

Astuno is retained when a matter sits at the intersection of sanctions, export controls, and foreign investment review, or when the stakes demand counsel with genuine agency experience and a track record in contested proceedings. He has secured OFAC delistings for sanctioned individuals and entities, negotiated National Security Agreements for foreign acquirers of U.S. businesses in critical-technology and infrastructure sectors, and submitted voluntary self-disclosures to OFAC, BIS, and CBP. He has also testified as an expert witness on CFIUS matters in federal court in a case involving a presidential divestment order, a credential held by a very small number of practitioners.

His practice spans both preventive counsel and active defense. Sophisticated clients, co-counsel, and referring firms turn to Astuno for command of the full regulatory lifecycle: compliance program design, agency filings, licensing, voluntary disclosure, and enforcement. He is particularly well-suited for high-net-worth individuals and corporations with cross-border exposure, foreign acquirers navigating CFIUS, and clients in high-risk jurisdictions where FCPA exposure compounds sanctions risk.

Sanctions, Export Controls & Customs

  • OFAC Delisting Petitions. Represented sanctioned individuals and entities in delisting petitions before OFAC, restoring access to the U.S. financial system.
  • OFAC Licensing. Advised foreign companies on sanctions compliance, including obtaining OFAC licenses for transactions in sanctioned jurisdictions.
  • Voluntary Self-Disclosures. Prepared and submitted voluntary self-disclosures to BIS, OFAC, and CBP, managing client exposure and agency engagement throughout.
  • CBP Seizure Proceedings. Represented a foreign buyer in seizure proceedings before U.S. Customs and Border Protection.
  • Semiconductor Compliance Program. Designed and implemented customized sanctions and export-controls compliance policies for a global semiconductor manufacturer.

CFIUS & Foreign Investment

  • CFIUS Filings. Represented sovereign wealth funds and their portfolio entities in filings before CFIUS, navigating national security reviews for investments in sensitive sectors.
  • National Security Agreements. Negotiated National Security Agreements on behalf of foreign acquirers of U.S. businesses in critical-technology and critical-infrastructure sectors.
  • CFIUS Expert Testimony. Testified as an expert witness on CFIUS matters in federal court in a case involving a foreign acquirer subject to a presidential divestment order.

Anti-Corruption, Trade & Other Regulatory

  • FCPA Compliance. Counseled a federal contractor on FCPA compliance in a high-risk conflict zone.
  • Anti-Kickback Compliance. Advised a prime contractor on anti-kickback compliance and supported federal agency proposal submissions.
  • FARA & Trade Compliance. Advised foreign governments subject to FARA registration on trade compliance and conflict resolution.
  • Investment-Treaty Arbitration. Represented investors in international arbitrations under bilateral investment treaties (BITs).
  • World Bank Mandate. Advised the Government of Nigeria on civil justice reforms as part of a World Bank consulting mandate.
  • Securities / Digital Assets. Represented defrauded investors in claims against the issuer of cryptocurrency-based securities and advised on related SEC administrative proceedings.
  • Pro Bono. Represented individuals in asylum proceedings before U.S. immigration authorities.
  • Economic Sanctions (OFAC)
  • Export Controls (BIS / EAR)
  • CFIUS & Foreign Investment Review
  • Anti-Corruption & FCPA Compliance
  • FARA & Lobbying Regulation
  • Customs & International Trade