Kara M. Bombach

Kara M. Bombach

Shareholder

Kara Bombach assists companies to lawfully export goods, technology and services around the globe. She places significant emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Sudan), entities and individuals. Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense.

She has significant experience advising national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anticorruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

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Capabilities

Experience

  • Enhanced global anti-corruption compliance program of Fortune 50 company consistent with elements of "effective compliance program" under OECD and US DOJ guidelines.
  • Designed Global Anticorruption Policy and implementing procedures for major multinational retailer.
  • Conducted in-country risk assessments and compliance program enhancements for U.S. companies’ subsidiaries in Argentina, Brazil, Chile, South Africa, and elsewhere.
  • Serves as outside counsel to The Boeing Company on export controls and economic sanctions matters.
  • Achieved resolution of multi-agency, multi-year export violation matter for armed security service provider with no monetary or administrative penalties.
  • Achieved resolution of multi-country OFAC economic sanctions violations disclosure matter, with no monetary or administrative penalties.
  • Achieved OFAC delisting of entities designated on OFAC’s list of Specially Designated Nationals (SDNs).
  • Successfully delivered global economic sanctions compliance program enhancements for household brand name food and beverage manufacturer.
  • Represented Canon Inc. before the Committee on Foreign Investment in the United States for its acquisition of Molecular Imprints, Inc.
  • Represented AB Volvo before the Committee on Foreign Investment in the United States for the sale of its aerospace business to GKN plc for £700m.
  • Advised TTM Technologies, Inc. in acquisition of Meadville Holdings, Ltd. printed circuit board business (total transaction value of approximately US$900 million).
  • Negotiated Special Security Agreement (SSA) with U.S. Department of Defense on behalf of U.S. company acquired by foreign investor.
  • Prepared, notified and negotiated approval by CFIUS on behalf of U.S. engineering services firm acquired by a UK company.
  • Advised Goldman Sachs International on tender offer for 100% of shares in Polish real estate developer, ROBYG S.A.
  • Advised Rentokil Initial plc in its acquisition of The Steritech Group, Inc. for $425 million.
  • Advised Exactech, Inc. in its sale to private equity fund TPG Capital for $640 million.
  • Intern, United Nations International Atomic Energy Agency Headquarters, Vienna, Austria, 1995-1996

Recognition & Leadership

  • Co-Chair, Cuba Practice, Chambers Latin America Guide, Corporate/Commercial: International Firms, (Band 3), 2018
  • Team Member, "Corporate & Finance - International Counsel in Latin America (Florida-Based)," Chambers Latin America Awards, 2017
  • Listed, Super Lawyers magazine, Washington, D.C. Super Lawyers, "Rising Star," 2013
  • Member, American Bar Association
    • Steering Committee, Aerospace & Defense Industries Committee, Section of International Law and Practice (2014-2015)
    • Member, National Security Committee
    • Vice Chair, Export Controls and Economic Sanctions Committee, Section of International Law and Practice (2010-2011)
  • Member, Association of Women in International Trade
  • Member, District of Columbia Bar Association, International Law Section
  • Member, International Bar Association, Anti-Corruption Interest Group and Women's Interest Group
  • Member, Society for International Affairs
  • Outside General Counsel to ALESA (American League for Export and Security Assistance – members include major multinational aerospace and defense companies)

Credentials

Education
  • J.D., Boston University School of Law
    • Concentration in International Law, with honors
    • Managing Editor, Boston University International Law Journal
    • Member, Phi Delta Phi Legal Honor Society
  • A.B., Cornell University
  • University of Vienna, Vienna, Austria
Admissions
  • District of Columbia
  • Maryland
Languages
  • French
  • German