Caroline J. Watson

Export Controls

• Obtained Technical Assistance Agreements (TAAs) for defense company's Direct Commercial Sales of Significant Military Equipment involving multiple countries. 
• Conducted independent internal investigation on behalf of multinational technology company into intra-company shipments and data-sharing involving China without export licensing, and represented company in disclosing the findings to BIS, successfully resolving the matter with a Warning Letter. 
• Obtained favorable BIS export classification determinations for industrial equipment manufacturer's electric motor product lines via Commodity Classification Automated Tracking System (CCATS) request, advocating against controls for specially designed military items. 
• Conducted self-classifications of defense articles under the ITAR and of dual-use products under the EAR on behalf of clients in numerous industries, including aerospace, vehicle, maritime, industrial machinery, software, and tactical gear manufacturers. 
• Obtained BIS export licenses on behalf of pharmaceutical company to export controlled substances to multiple countries for clinical studies and research and development (R&D) collaboration.
• Represented medical device company in disclosing product shipment(s) to Russia without required export licensing, successfully resolving the matter with a Warning Letter from BIS. 

Economic Sanctions

• Conducted internal investigation of alleged North Korea sanctions violations for large Asian energy trading company and represented company in disclosing findings to OFAC, successfully resolving the matter with a No Action Letter from OFAC.
• Advised publicly traded U.S. companies on proposed Cuba operations and transactions, particularly for travel, retail, or humanitarian activities, including on eligibility for general authorization(s) as well as on internal controls and mitigation measures for compliance risk. 
• Obtained OFAC specific license on behalf of U.S. technology company to authorize payment of exit tax required by Russian government in order to divest of Russian holdings. 
• Represented Middle Eastern trading companies before OFAC and DOJ in successfully resolving potential enforcement actions relating to their respective oil tankers held hostage in Houthi-controlled ports.
• Advised national NGO and intergovernmental organization concerning U.S. sanctions compliance and FTO risk for operating in Houthi-controlled areas of Yemen and recommended compliance and risk-mitigation measures. 
• Advised U.S. and multinational corporations with continued Russia presence or operations concerning U.S. sanctions compliance and risk, including derivative or secondary sanctions risk.

ICTS and Connected Vehicle

• Developed and advised on compliance programs for automotive original equipment manufacturers (OEMs) and importers to conduct supply chain due diligence and filings required under the Connected Vehicle regulations.
• Advised U.S. technology company concerning sourcing and supply chain development for commercial fleets to be operated globally.
• Conducted assessment of software developer's status as owned by, controlled by, or subject to the jurisdiction of control of, a foreign adversary under the Connected Vehicle regulations 
• Evaluated Tier 1 supplier's product offerings for compliance with Connected Vehicle regulations.  
• Advised on and prepared Declarations of Conformity for connected vehicle manufacturing and importing operations. 

CFIUS and Outbound Investment

• Represented aerospace, defense, and firearm manufacturers in mandatory declarations and voluntary notices to CFIUS, successfully obtaining clearance for foreign investment and acquisition transactions without the imposition of mitigation measures.
• Advised U.S. sellers and foreign buyers concerning mandatory and voluntary filings to CFIUS with respect to proposed investment and acquisition transactions.
• Advised U.S. technology company on restrictions or requirements for proposed investment transactions involving China under the Outbound Investment regulations. 

ATF

• Represented defense contractor in ATF classification request for multiple product lines and manufacturing phases involving contract manufacturers. 
• Advised defense companies concerning ATF licensing and compliance requirements for their respective operations.
• Obtained various types of ATF Federal Firearms Licensing (FFLs) and Federal Explosives Licensing (FELs) on behalf of defense manufacturers and importers.
• Advised on ATF approvals and permits required for regulated firearm and destructive device transfers, imports, and exports. 

• Legal Intern, Immigration and Customs Enforcement, Office of Acquisition Management, Suspension and Debarment Division, U.S. Department of Homeland Security, 2013 - 2014
• Legal Intern, Immigration and Customs Enforcement, Office of Principal Legal Advisor, Commercial and Administrative Law Division, U.S. Department of Homeland Security, 2013 - 2014

• The Lexology Index: Trade & Customs: International Sanctions, 2026 (formerly Who's Who Legal)
• DC Bar Capital Pro Bono Honor Roll, 2019 - 2020