Jeffrey W. Cottle

Full Profile

Jeffrey W. Cottle focuses on white collar crime and compliance matters, with particular emphasis on fraud, anti-bribery & corruption, anti-money laundering, trade sanctions, and export controls. Jeff supports a global client base on complex, multi-jurisdictional matters and helps organizations navigate regulatory and enforcement risk with clarity and confidence.

Before moving into private practice, Jeff held senior in-house compliance counsel roles at major corporations headquartered in the US, Europe, and Australia. He has led compliance and anti-corruption functions for companies operating in higher risk jurisdictions across the Middle East, Africa, Asia, Europe, and Latin America. He has contributed to critical decision making at every level of management, from strategic board level discussions to operational issues at remote work locations.

Admissions

• District of Columbia
• Maryland
• Registered Foreign Lawyer, England and Wales

Education

• J.D., University of Virginia School of Law
• B.A., magna cum laude, Georgetown University

Memberships

• Governor, Board of Governors, St. Mary’s University Twickenham, London
• Chair, Global Compliance Forum, Dublin and Frankfurt
• Chair, Speaker, Thought Leader Global, Amsterdam
• Chair, Speaker, C-5 Anti-corruption Nordics, Oslo, Stockholm
• Speaker, Maritime Anti-Corruption Network, Copenhagen
• Speaker, Cercle de le Compliance, Paris

Experience

Compliance experience

• Chief Compliance Officer for US Fortune 50 company responsible for sanctions, export controls, anti-corruption, and anti-money laundering.
• Implementing a risk-based sanctions compliance program for a global dual-listed resources company with operations in Latam, APAC, the Middle East and Africa.  
• Acting as lead US sanctions counsel representing clients in direct engagement (enforcement actions and advisory) with OFAC, BIS, DOJ and DDTC.  
• Lead compliance counsel, both as in-house and outside counsel, on all aspects of compliance risk for investments of global companies in resources, manufacturing and aerospace/defense businesses.
• Advised on anti-bribery and corruption and fraud risk for a global organization with frameworks aligned with US, UK and European regulatory expectations, including third party risk, whistleblowing response, and governance controls relevant to the businesses.
• Advised various investors on anti-bribery and corruption and sanctions risks linked to procurement, third party engagement and investment structures in Middle East, Russia, Africa and Latin America, including alignment with UK, EU and US compliance expectations.
• Assisting a Turkish conglomerate with multinational operations in diverse product sectors design and implementing custom full-spectrum compliance program, including risk-based ABC, sanctions, export control and AML compliance policies and procedures, as well as implementation of same. 
• Providing strategic and tactical sanctions compliance advice to a French FMCG company, including designing sanctions program to meet increasingly risky markets and managing integration of acquisitions and JVs into company’s compliance program, handling multiple investigations into breaches of law and policy in high-risk locations, including voluntary self-disclosures to enforcement authorities in multiple jurisdictions.
• Assisted a highly regulated Asian financial institution respond to and remediate sanctions controls failures that resulted in payment to a Specially Designated National (SDN). Performed in-depth analysis of in-place compliance program and controls systems and conducted root cause and gap analyses. Provided tailored remediation actions as well as general compliance program improvements aligned with US and UK regulatory expectations based on root cause and gap analyses. Provided additional advice and support to client in implementing remediation and improvement actions, including providing training to key personnel and Board members, and updating and revising guidance to suit business needs. Currently supporting client in making voluntary self-disclosure to US regulator and with ongoing implementation advice.
• Represented Norwegian publicly held technology company, specializing in semiconductor development, in the acquisition of a US semiconductor firm with ITAR-controlled technology, pursuant to CFIUS requirements.
• Counseled US and European aerospace companies on ITAR, EAR and other export control and sanctions compliance regimes. Established programs and ensured implementation at international subsidiaries and joint ventures.
• Counseled Middle Eastern airline on US and EU export control regimes related to Russia and other Middle Eastern countries.
• Counseled Middle Eastern airline on parameters of providing flights to SDNs and UK/EU Blocked Persons.
• Counseled Middle Eastern aviation company on export control issues related to modifications of US-origin aircraft.
• Counseled international aviation companies on compliance with various non-SDN US export and sanctions restrictions (UFLPA list, BIS entity list, UVL list, etc.).
• As in-house counsel, managed all aspects of compliance for trading operations of $85B global extractives company, including, but not limited to, terms & conditions, tactical advice on trading activities, strategic advice on market risks, crisis management, litigation, and investigations.

Investigations experience

• As in-house counsel:
  • managed international aerospace company’s response to multi-jurisdictional anti-corruption investigations by criminal authorities in the US, UK and Europe, including interactions with relevant regulators. 
  • managed investigations of potential breaches of ITAR, EAR, US and UK economic sanctions regimes
  • undertook due diligence investigations of vendors, sales agents, distributors, and other sources of third-party risk.
  • investigated allegations of inappropriate conduct by senior officers of company.
• Investigation of potential violations of US export control regulations (EAR) by European aerospace & defense company for transfer of technical data to unlicensed nationals.
• Investigation of anti-corruption and fraud allegations involving African subsidiary of international aviation company related to “charitable donations” to government agencies. 
• Investigation of potential violations of US export control regulations (ITAR and EAR) by Asian aerospace company related to employee storage and access to technical data.
• Investigation of potential violations of several anti-corruption regimes by European aerospace company related to gifts and gratuities to government officials in several countries, including VSD and other interactions with DOJ and SFO. 
• Investigation of potential breaches of applicable economic sanctions regimes related to sales by Middle Eastern distributors of European aerospace company.
• Investigation of Middle Eastern airline’s flights to sanctioned countries, operations using sanctioned vendors, prohibited government services, including VSD to OFAC.