John A. Detzner
Of Counsel,
Washington, DC
Practice Area
International Trade Policy and Regulation
Education
Harvard Law School, J.D., 1980
Harvard College, A.B., 1977
Languages
Spanish
Bar and Court Admissions
U.S. Supreme Court
U.S. Court of Appeals for the District of Columbia
U.S. Court of Appeals for the Federal Circuit
U.S. Court of Federal Claims
U.S. District Court for the District of Columbia
U.S. District Court for the Northern District of Illinois
U.S. Court of International Trade
District of Columbia
Illinois
Other Professional Affiliations
American Bar Association
District of Columbia Bar
Inter-American Bar Association
Inter-American Dialogue
Office Location:
Neville Peterson LLP
1400 16th Street, N.W.
Washington, D.C. 20036
Phone: (202) 776-1155 Fax: (202) 861-2924
Email: jdetzner@npwdc.com
John A. Detzner, resident in the firm’s Washington, D.C. office, has extensive experience counseling domestic and foreign clients in international trade policy and regulation, particularly the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), the Foreign Corrupt Practices Act (FCPA), sanctions programs administered by the Office of Foreign Assets Control (OFAC), and U.S. anti-boycott laws and regulations.
In these areas Mr. Detzner represents U.S. and foreign companies and individuals in criminal and administrative investigations and enforcement actions; conducts internal investigations and prepares related voluntary disclosure reports; manages internal and external audits; supervises due diligence reviews of prospective mergers and acquisitions; develops and implements compliance programs, training programs, and other corrective actions; and assists clients in commodity jurisdiction and product classifications, advisory opinions, licensing and other governmental approvals, and compliance planning related to overseas procurement activity, joint venture partners, distributors, and marketing representatives. He is fluent in Spanish and conducts his work in both English and Spanish.
Mr. Detzner also advises clients on Buy American Act and Trade Agreements Act compliance and related offshore procurement planning; Defense Department FMS and FMF Programs; ATF-controlled imports; and U.S. import regulations concerning rules of origin, tariff preferences, ruling requests, and seizures.
Mr. Detzner serves on the Steering Group of the ABA Committee on Export Controls and Economic Sanctions. He also serves as a volunteer attorney for the Small Business Administration’s Export Legal Assistance Network.
In 2011 he was appointed an External Member of the Sanctions Committee of the Inter-American Development Bank. He is a member of the Board of Advisers to the Foreign Corrupt Practices Act Reporter, and is a former co-chair of the ABA Task Force on International Standards for Corrupt Practices.
Representative Matters:
- Implemented, in coordination with an ongoing Justice Department criminal investigation and related State Department directed disclosure request, a comprehensive internal ITAR compliance review of affiliated U.S. and foreign companies located in five countries on three continents; working closely with the corporate director of export compliance, provided daily related export compliance counseling and corrective actions, prepared numerous related voluntary and directed disclosure reports, assisted the companies in implementing additional corrective actions and compliance programs, provided training, and coordinated related efforts and communications with State Department enforcement officials.
- Supervised internal ITAR and EAR reviews of foreign national and dual national employees of a multinational company’s approximately 35 facilities throughout the world, and prepared related voluntary and directed disclosure reports to State and Commerce Departments.
- Coordinated a publicly traded company’s internal investigation of alleged FCPA violations by the company’s foreign subsidiary, and prepared and presented a related voluntary disclosure report to the Justice Department and the SEC, resulting in no action taken against the company.
- Conducted an internal FCPA review of a U.S. parent company’s foreign subsidiary located in Latin America, including Spanish language interviews and review of Spanish language documents and correspondence, assisted the parent company with confirmation and evaluation of facts, implemented related corrective actions, and provided related training in Spanish.
- Prepared a multinational telecommunications company’s comprehensive Commerce Department classification request involving a new product, multiple parts and components, related development and operating technology, and related development and operating software, and obtained a favorable response enabling the company to plan and implement offshore manufacturing activity while ensuring full EAR compliance.
- Prepared a small company’s commodity jurisdiction request for a new product developed under a Defense Department contract as a component of a military defense system, and obtained a State Department favorable determination of EAR jurisdiction to simplify the company’s related international marketing and sales activity.
- Assisted a multinational manufacturing company with OFAC reviews involving de minimis issues, foreign subsidiary activity, and potential U.S. person involvement, and prepared a related OFAC advisory opinion request resulting in OFAC’s confirmation of permissibility of the proposed activity.
- Assisted numerous private and publicly held companies in due diligence compliance reviews of proposed acquisitions, and coordinated and reviewed related voluntary disclosures by target companies, and related indemnification provisions, prior to acquisition.
- Coordinated and conducted internal investigations for numerous large and small U.S. and foreign companies in the aerospace, defense, telecommunications, computer, software, electronics and other manufacturing industries, prepared over 100 voluntary and directed disclosure reports, and assisted the companies in developing and implementing related compliance programs and corrective actions.
Publications:
“FCPA, ITAR, EAR y OFAC: Alcance Extraterritorial a Compañías No Estadounidenses y Programas Relacionados a su Cumplimiento,” Revista Derecho de los Negocios, No. 234, March 2010 (Madrid).
“Compañías y Personas No Estadounidenses y la FCPA: La Ley Contra Prácticas Corruptas en el Extranjero,” Foreign Corrupt Practices Act Reporter (April 2010).
“Model Foreign Consultant Compliance Program for Foreign Corrupt Practices Act,” ABA-CLE National Institute on the Foreign Corrupt Practices Act: 2002, 2001, 2000, 1999, and 1998.
“Model Company Policy and Procedure for Foreign Corrupt Practices Act,” ABA-CLE National Institute on the Foreign Corrupt Practices Act: 2002, 2001, 2000, 1999, and 1998.
“Challenges Facing Public Sector Procurement in the United States,” Inter-American Development Bank, Seminar on Efficiency and Transparency in Public Sector Procurement, February 26-27, 1998 (co-author).
“In Chile, Environmental Law Awaits Regulations,” National Law Journal, December 23, 1996, Section C, pp. 4-6 (co-author).
“Chile’s Environmental Framework Law: Considerations for Foreign Investors,” NAFTA and the Environment, Martinus Nijhoff Publishing, 1996 (co-author).
“Doing Business in Post-Devaluation Mexico,” Inter-American Trade and Investment Law, February 1995 (co-author).
“Foreign Investment in Chile,” Corporate Counsel’s International Adviser, September 1994.
Pro Bono Activities:
Mr. Detzner’s pro bono work has included legal assistance to the Chilean Truth and Reconciliation Commission, to the family of a U.S. citizen killed in Chile, and to the family of two Chilean citizens killed in Argentina. For many years he served pro bono as Legal Counsel of the Center for Justice and International Law in Washington. On behalf of Human Rights Watch and at the request of the Special Prosecutor of the Transitional Government of Ethiopia, he prepared an amicus brief to the Ethiopian Supreme Court regarding its review and application of international human rights law in domestic criminal cases against members of the former Mengistu regime. In this area of international law, he is the author of a book in Spanish entitled Tribunales Chilenos y Derecho Internacional de Derechos Humanos (Santiago 1988), and articles in Spanish, including “Utilización de mecanismos internacionales en la protección de derechos humanos: el caso chileno,” Revista IIDH, 6 (1987): 3-20.
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