Cheryl Palmeri

Ms. Palmeri is an associate in the Government Contracts, Investigations & International Trade Practice Group in the firm's Washington, DC office.

Areas of Practice

Ms. Palmeri focuses on issues and investigations involving U.S. and other anti-corruption laws, U.S. export and import controls, U.S. sanctions regulations, and other U.S. trade compliance matters.

Education

• J.D., University of Michigan, 2011, cum laude, Best Oral Advocate, Henry M. Campbell Moot Court
• B.A., University of California, Los Angeles, 2005, summa cum laude, college honors, Phi Beta Kappa, National Merit Scholar

Clerkships

• Intern to the Honorable Stephen H. Glickman, District of Columbia Court of Appeals

Admissions

• California
• District of Columbia

Languages

• Spanish

Foreign Corrupt Practices Act

• Advised U.S. apparel company on investigation related to Chinese corruption allegations
• Conducted FCPA risk assessment and prepared anti-corruption law compliance training for U.S. retail company
• Assisted multinational private equity firm to conduct internal investigation related to alleged corruption in company’s Middle Eastern operations

 Export and Import Controls

• Counseled multinational oil pipeline operator on applicable export and import controls
• Advised international engineering and design company on technology transfer under the International Traffic in Arms Regulations (ITAR)
• Assisted U.S. aerospace company to review and disclose third party agent’s diversion to U.S. Commerce Department, Bureau of Industry & Security (BIS) and U.S. State Department, Directorate of Defense Trade Controls (DDTC)
• Provided advice to global automotive company on distributor export compliance
• Represented U.S. defense contractor in responding to Department of Commerce subpoena
• Prepared comprehensive customs compliance training for U.S. retailer

Sanctions

• Assisted major U.S. bank in responding to OFAC inquiry regarding accounts maintained by prohibited parties
• Advised international private equity firm on compliance with U.S. sanctions on Iran

Other Experience

• Advised U.S. consulting firm on Foreign Agents Registration Act (FARA) compliance and registration
• Counseled U.S. defense contractor on internal investigation into alleged employee misconduct and self-dealing
• Assisted in the defense of a Japanese automobile parts manufacturer in an enforcement action by the U.S. Department of Justice, Antitrust Division

Pro Bono

• Represented a client from the Central African Republic in application for U.S. political asylum

Articles

• "Total Settlement of FCPA Charges," Global Trade Law Blog, June 6, 2013
• Co-author, "New "Beast" Rules Lessen the Export Control Burden," Global Trade Law Blog, May 7, 2013
• Co-author, "Line in the Sand: Siemens Argentina Case Limits Personal Jurisdiction Under the FCPA," Global Trade Law Blog, March 8, 2013
• Co-author, "Iran, China, and Prison: A Recap of 2012’s Major Export Enforcement and Embargo-Related Criminal Cases," Global Trade Law Blog, January 9, 2013
• Co-author, "What’s In the New FCPA Resource Guide: Some Welcome Clarity and Unexpected Muddling," Global Trade Law Blog, December 6, 2012
• Co-author, "Smaller FCPA Story But We’re Sure You’re Following It: DOJ Issues New Opinion Procedure Releases," Global Trade Law Blog, December 6, 2012
• Co-author, "Update on U.S.-Myanmar Relations: The Thaw Continues," Global Trade Law Blog, October 19, 2012
• Co-author, "OFAC Authorizes the Exportation of Financial Services to and New Investment in Myanmar," Global Trade Law Blog, August 17, 2012
• Co-author, "Department of Justice Obtains First Forfeiture Judgment Under the Kleptocracy Asset Recovery Initiative," Global Trade Law Blog, July 11, 2012
• Co-author, "BIS Creates a Temporary Holding Classification Number on the CCL," Global Trade Law Blog, June 7, 2012 
• Co-author, "OFAC’s (Very) Long Arm: GAM Settlement May Illustrate the ITR’s Expanding Reach," Global Trade Law Blog, June 7, 2012
• Co-author, "Loosening Up: New Developments in Sanctions Against Myanmar," Global Trade Law Blog, May 1, 2012
• Co-author, "A Noble Pursuit? SEC Brings FCPA Charges Against Individual Oil Services Executives," Global Trade Law Blog, Law360, March 14, 2012
• Co-author, "State Department (Finally) Proposes Amendments to ITAR Brokering Provisions," Global Trade Law Blog, January 18, 2012 
• Co-author, “Longest Prison Sentence Yet in FCPA Case,” Government Contracts Blog, November 16, 2011
• Co-author, “DOJ Targets FCPA and Anti-Trust Violations Jointly,” Government Contracts Blog, November 16, 2011
• Co-author, "Sixth Circuit Skirts Jurisdictional Issue in Denying Reinstatement to Alleged SOX Whistleblower," Labor & Employment Law Blog, July 1, 2010