Eric J. Rudolph’s work focuses on compliance with economic sanctions and U.S. export controls.
An attorney by experience and training, Mr. Rudolph has led, managed and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa and Asia); internal investigations; economic and trade sanctions, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR) counseling; jurisdiction and classification analyses; and training efforts.
In his practice, Mr. Rudolph focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities. Additionally, he has significant experience in working with companies operating under government-appointed compliance monitors/officials, including serving as part of the monitor team in a sanctions and export controls case involving criminal and civil settlements with the Department of Justice (DOJ), Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS).
Mr. Rudolph also assisted the sanctions compliance leadership at the New York branch of one of the world’s largest banks, operating under the oversight of a monitor imposed by NYDFS, with the design and implementation of enhancements to its OFAC compliance program. His experience with sanctions matters includes advising clients on compliance with various programs administered by OFAC; review of compliance programs; review and recommendations on screening and due diligence procedures; investigation of potential violations; advising on sanctions matters in the context of M&A due diligence and integration; and assisting with voluntary self-disclosures and remedial measures.
Previously, Mr. Rudolph worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm before joining the Big 4. Mr. Rudolph also worked for 15 years as an in-house lawyer, including acting as a General Counsel, with manufacturing companies in various industries and has substantial experience in advising Boards and all levels of global executive leadership and management on all aspects of compliance. In addition to sanctions and export controls compliance, he also has experience with anti-bribery matters (Foreign Corrupt Practices Act), including policies and procedures, investigations, voluntary disclosures and remediation; and in U.S. Customs Service matters.
Mr. Rudolph previously served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACTPN), the U.S. government’s senior trade advisory panel and, in that capacity, participated in the drafting of ACTPN reports to the President, the Congress, and the Office of the U.S. Trade Representative on several free trade agreements.