A closer look at the experience behind our team.

Jeff brings clients the judgment of a senior government attorney who advised Commerce Department leadership on export controls, technology security, and national-security enforcement at the highest levels of government. Before founding the firm, he served as Acting Chief Counsel for Industry and Security at the U.S. Department of Commerce. In that role, he was the principal legal advisor to leadership of the Bureau of Industry and Security (BIS) and oversaw the Office of Chief Counsel’s Enforcement and Litigation Division, Information and Communications Technology and Services (ICTS) Division, and Policy, Legislation and Regulation Division. The Office of Chief Counsel also provided legal support for BIS’s antiboycott compliance program under the Export Administration Regulations. He advised senior Department officials on export controls, export enforcement, technology security, supply-chain security, licensing policy, rulemaking, ICTS authorities, and related national-security matters.

As Division Chief for Enforcement and Litigation, Jeff led the legal office responsible for advising BIS export-enforcement officials on investigations, voluntary self-disclosures, charging decisions, administrative prosecutions, settlements, and enforcement policy. Under his leadership, the office brought a record number of administrative enforcement actions, including the two highest standalone administrative penalties in the agency’s history. He worked closely with export-enforcement agents, federal prosecutors, and interagency partners to strengthen enforcement of U.S. export controls. He helped implement the Department of Commerce’s joint Disruptive Technology Strike Force with the Department of Justice. In that role, he worked directly with U.S. Attorneys’ Offices across the country and DOJ’s National Security Division to prevent critical technology from being acquired by nations hostile to the United States. He also partnered with the Department of the Treasury’s Office of Foreign Assets Control and the Department of State’s Directorate of Defense Trade Controls to coordinate joint administrative enforcement resolutions.

Jeff played a leading role in the development, implementation, and enforcement of major export-control and technology-security initiatives, including matters involving advanced technologies, foreign-adversary risks, and the Foreign Direct Product Rule. He received the Secretary’s Gold Medal Award for work on a novel export-enforcement action involving violations of the Foreign Direct Product Rule that resulted in a $300 million administrative penalty.

Earlier at BIS, as Assistant Division Chief for Enforcement and Litigation, Jeff coordinated the government’s litigation surrounding the Section 232 steel and aluminum tariff exclusion program. He led the litigation team assisting the Department of Justice in defending that litigation before the U.S. Court of International Trade — including record development and settlement negotiations — while restructuring BIS’s exclusion-review process and assisting in the drafting of related Presidential Proclamations.

In private practice, Jeff was a partner at two national law firms, where he represented companies and individuals in government investigations, enforcement actions, internal investigations, and compliance matters involving export controls, sanctions, anti-money laundering, and financial crimes. His matters included representing a company owner, post-indictment, in a criminal export-enforcement case that resulted in dismissal of all charged export-violation counts; representing companies in connection with Department of Justice investigations into export-control violations; representing individuals in a Department of Justice international money-laundering and bribery investigation; and representing a firearms manufacturer in a Department of Justice investigation involving export-control and firearms violations.

Jeff also served as Managing Director and General Counsel for Anti-Money Laundering at Citigroup, advising senior business leaders, compliance personnel, risk professionals, and corporate leadership on anti-money laundering, sanctions, regulatory enforcement, and financial crime matters. He managed significant regulatory issues involving federal banking regulators and advised on matters involving the Bank Secrecy Act, economic sanctions, fraud investigations, and complex compliance challenges facing a global financial institution.

Earlier in his career, Jeff spent more than fifteen years as a federal prosecutor in the U.S. Attorney’s Office for the District of Columbia, including as Deputy Chief of the National Security Section and Special Counsel for National Security to the U.S. Attorney and as Deputy Chief of the Organized Crime and Narcotics Trafficking Section. During his government service, he investigated and prosecuted matters involving terrorism, export controls, sanctions, espionage, money laundering, organized crime and Racketeer Influenced and Corrupt Organizations Act (RICO) enterprises, narcotics trafficking, and other complex federal offenses, serving as lead counsel in thirty-six felony trials. Before that, Jeff served as a Special Assistant in the Office of the NASA Administrator, advising on congressional affairs and international policy initiatives, including matters involving the U.S. Department of State and the President’s National Security staff.

Jeff’s experience spans the full life cycle of export controls, sanctions, technology security, and national-security regulatory matters, from investigations and voluntary self-disclosures through charging decisions, settlement negotiations, administrative litigation, and compliance remediation. His leadership experience across the U.S. Department of Commerce, combined with his years as a federal prosecutor, gives him a clear sense of what government agencies look for, how they evaluate cases, and how matters are ultimately resolved.

Tony’s career has been built at the intersection of technology security, export enforcement, counterterrorism, and foreign investment review through decades of service as a federal prosecutor and in legal leadership roles at the U.S. Departments of Justice and Commerce.

At the U.S. Department of Commerce, Tony was Chief of the Technology Security Division within the Office of Chief Counsel for Industry and Security and previously Acting Chief Counsel for the Office of Technology Security. In those roles, he led the Department’s legal efforts supporting the Information and Communications Technology and Services (ICTS) program under Executive Order 13873, advised on technology security, supply-chain security, export controls, enforcement matters, and national-security rulemaking, and worked closely with Department leadership and interagency partners on emerging technologies and foreign-adversary risks. He helped build and operationalize the Department’s ICTS regulatory program and led the Department’s first prohibition issued under those authorities, barring a Russia-based cybersecurity company’s U.S. subsidiary from providing its products and services to U.S. persons. The prohibition was issued alongside coordinated Entity List additions and OFAC sanctions designations.

Tony also led the Policy, Legislation and Regulation Division within the Office of Chief Counsel for Industry and Security. In that capacity, he supervised the legal team responsible for export-control regulatory, policy, and legislative matters under the Export Administration Regulations (EAR), advised on export-control rulemakings and national-security trade policies affecting critical technologies, and provided legal counsel on export-enforcement investigations, charging decisions, settlements, and administrative enforcement proceedings. He also evaluated proposed foreign acquisitions of U.S. businesses for national-security concerns in support of the Department’s participation in the Committee on Foreign Investment in the United States (CFIUS).

At the Department of Justice, Tony was Deputy Chief of the Counterterrorism Section, where he provided leadership and strategic oversight for investigations and prosecutions involving international terrorism and other national-security threats. He coordinated complex investigations, prosecutions, and interagency initiatives involving the FBI, the intelligence community, the Department of Defense, the Department of State, and foreign government partners, and oversaw classified litigation under the Classified Information Procedures Act (CIPA). He advised senior Department officials on terrorism, sanctions evasion, terrorist financing, hostage-taking, material support networks, and other sensitive national-security matters.

Tony also served as counsel in the Department of Justice’s Foreign Investment Review Section, advising on national-security risks arising from foreign investments and acquisitions reviewed by CFIUS. His work involved transactions affecting critical technologies, cybersecurity, telecommunications, energy, transportation, and other sensitive industries, as well as the development and negotiation of mitigation measures addressing foreign ownership, control, or influence risks.

Following his government service, Tony was a partner at a nationally recognized Washington, D.C. litigation boutique, where he represented U.S. servicemembers, civilians, and Gold Star families in litigation under the Anti-Terrorism Act and the Foreign Sovereign Immunities Act arising from acts of international terrorism.

Earlier in his career, Tony spent more than twenty years as an Assistant United States Attorney in the District of Columbia, including as Chief of the Felony Trial Section; as Chief and Deputy Chief of the Misdemeanor Section, which handled approximately 14,000 criminal cases annually; and as Export Control Coordinator and International Coordinator. During his tenure, he personally tried more than 100 jury trials, including more than thirty Felony I cases, and he participated in drafting more than thirty appellate briefs resulting in ten published opinions. As a member of the National Security Section, he investigated and prosecuted matters involving terrorism, espionage, export-control violations, sanctions offenses, counterproliferation, and other threats to national security. He conducted investigations and prosecutions under the EAR, the International Emergency Economic Powers Act (IEEPA), the Arms Export Control Act (AECA), the International Traffic in Arms Regulations (ITAR), and OFAC-administered sanctions programs.

Within that broader prosecutorial career, Tony handled numerous significant export enforcement, sanctions, counterproliferation, counterterrorism, and espionage cases. His export enforcement matters involved the unlawful export and diversion of sensitive U.S. technologies and strategic goods to Iran, China, Libya, and other destinations of concern. They included military antennas, UAV components, missile-related microprocessors, commercial aircraft diverted in violation of U.S. export controls, sonar systems, and other controlled technologies. He prosecuted an aircraft-diversion case that resulted in a $15 million BIS penalty, then reported as the largest export-enforcement penalty in the agency’s history. He also brought the first case charged under the federal narco-terrorism statute and prosecuted an export matter in which unlawfully exported electronic components were later recovered in improvised explosive devices used against U.S. forces in Iraq. He worked closely with BIS, the FBI, Homeland Security Investigations (HSI), federal law-enforcement and intelligence-community partners, and foreign law-enforcement partners on some of the government’s most sensitive national-security investigations.

Drawing on decades of leadership and experience in national-security matters across the U.S. Departments of Justice and Commerce, Tony advises clients with the perspective of a senior government attorney who has investigated, prosecuted, and regulated in the areas where his clients now operate. That vantage point informs how he counsels clients through export-control, sanctions, ICTS, and national-security investigations, voluntary self-disclosures, and regulatory matters, including what it takes to resolve them.

Debra brings clients more than two decades of experience in export controls, sanctions, international trade, and corporate compliance, much of it in senior in-house roles at Salesforce and Caterpillar. Her career has centered on applying complex trade requirements inside global companies and translating them into practical decisions affecting technology, transactions, supply chains, compliance systems, and business growth. Throughout her career, she has brought a business-oriented perspective to legal and regulatory issues, advising management on their impact on business operations and objectives.

At Salesforce, Debra served as Senior Corporate Counsel and Director of Global Trade Programs. She was the company’s lead trade attorney and subject-matter expert for international trade, focusing primarily on Commerce Control List Category 5-related export controls and sanctions. She built and developed Salesforce’s trade-compliance team and designed, developed, and implemented enhancements to enterprise trade-compliance programs so they could scale with the company’s rapid growth and global expansion through mergers and acquisitions and organic growth.

Previously, Debra spent a decade as Corporate Counsel for International Trade at Caterpillar, where she was a trusted advisor and subject-matter expert on international trade regulatory compliance, covering both dual-use and munitions requirements. She designed, developed, and implemented enhancements to enterprise-wide programs addressing anti-bribery, export controls and sanctions, customs, and antiboycott compliance, while also advising on general corporate and governance matters. Her work involved a complex worldwide distribution network and global operations spanning both the supply-chain and sales sides of the business.

Earlier, as an associate in the International Group at McGuireWoods in Washington, D.C., Debra advised on international business transactions and related regulatory and policy matters, including export controls, the Foreign Corrupt Practices Act, issues involving the Committee on Foreign Investment in the United States (CFIUS), the USA PATRIOT Act, international commercial and securities matters, trade and investment issues, and public international law.

Since 2023, Debra has maintained a legal and business consulting practice, advising businesses on efficiency, profitability, risk management, formation, restructuring, and growth across the business lifecycle.

Debra chaired the Association of Corporate Counsel’s Ethics and Compliance Committee until 2018, after previously serving as the Committee’s Secretary and Co-Vice Chair. She has also spoken and served as a panelist at national programs on global trade and compliance. At Women, Influence & Power in Law, she addressed developments in global trade; at TRACE, the intersection of due diligence, anti-bribery, and trade compliance; at the Ethisphere Global Ethics Summit, global trade concerns and their impact on compliance; at ACI’s Advanced Forum on Global Encryption, Cloud & Cyber Export Controls, China’s export control law and its application to encryption and cyber exports; and at Kharon, supply-chain challenges involving BIS military end-use and end-user rules and Customs withhold release orders.

Debra’s experience gives clients a regulatory perspective formed inside global companies responsible for applying these rules in practice. She understands not only the legal requirements but how they interact with technology, commercial decisions, transactions, supply chains, sales, and enterprise compliance systems. That in-house perspective complements the firm’s government, enforcement, and investigative experience in complex trade and national-security matters.

Phil serves as Director of Investigations for Beatrice & Asuncion, bringing clients the perspective of a federal agent who developed export-enforcement cases from inside the government.

A former Special Agent with the U.S. Department of Commerce’s Office of Export Enforcement, Phil has more than twenty-five years of federal investigative experience spanning export enforcement, counterproliferation, sanctions investigations, and other national-security matters. During his OEE career, he investigated violations of U.S. export controls, illicit procurement networks, sanctions-related conduct, and other threats to national security.

Phil held senior leadership positions within the Office of Export Enforcement, including as Assistant Special Agent in Charge of the Washington Field Office and Acting Unit Chief of OEE’s Headquarters Operations Unit, where he supervised teams of special agents and coordinated the nationwide dissemination of time-sensitive intelligence for investigative use. He later served in a dual role as Deputy Director of the Export Enforcement Coordination Center and as OEE’s Senior Liaison Officer to U.S. Customs and Border Protection’s National Targeting Center, helping coordinate export-enforcement and counterproliferation efforts among federal law-enforcement, intelligence, regulatory, and national-security agencies.

Over the course of his career, Phil worked extensively with BIS special agents, federal prosecutors, intelligence agencies, and international law-enforcement partners on investigations involving sensitive technologies, export-control violations, sanctions evasion, illicit procurement networks, and other national-security threats.

In addition to his investigative leadership roles, Phil was an FBI Task Force Officer and spent more than a decade training federal agents and intelligence analysts at the FBI Counterintelligence Training Center and the Department of Defense’s Joint Counterintelligence Training Activity, where he mentored generations of export-enforcement agents, analysts, and investigators.

Earlier in his career, Phil served as a Special Agent with the Treasury Inspector General for Tax Administration, conducting federal criminal investigations into threats, bribery, extortion, identity theft, and fraud affecting the federal tax system. He was named Special Agent of the Year and received a Department of Justice Public Service Award for his investigative work, as well as recognition from the President’s Council on Integrity and Efficiency for his contributions to the U.S. Government’s post-9/11 response.

Before that, Phil served with the Central Intelligence Agency, where he conducted more than 1,000 polygraph interviews and interrogations of CIA applicants, contractors, and employees, and served in the Counterespionage Group within the CIA’s Counterintelligence Center, coordinating investigative activity with other federal law-enforcement organizations. He obtained the initial admissions in a significant espionage matter that led to a federal conviction, and he received the CIA’s Certificate of Distinction for his contributions to a major counterespionage investigation.

Earlier still, Phil served with the Naval Investigative Service, where he adjudicated security clearances for naval personnel worldwide and served as a pre-publication review officer, screening materials intended for public release by naval military and civilian personnel.

With decades of investigative experience, Phil helps clients understand how export-enforcement investigations are initiated, developed, evaluated, and resolved. His background gives clients practical insight into government investigative approaches, enforcement priorities, voluntary self-disclosures, and interactions with federal law-enforcement and regulatory agencies.