Reid
Whitten

Partner•Office Managing Partner, London
LANGUAGES
French
LINKEDIN
Reid Whitten

Overview

Reid Whitten works with clients around the world to plan, prepare and succeed in global transactions—anticipating the international trade regulations that could disrupt their deals and positioning them ahead of the market. He is the managing partner of the firm’s London office and leads the firm’s CFIUS team and semiconductor industry team.

Advising clients around the world in the defense, aerospace, technology, semiconductor and banking industries, Reid supports clients in detecting and addressing potential compliance issues as well as conducting investigations and defending against enforcement actions. He advises in the areas of:

  • Economic sanctions
  • Export controls (EAR)
  • Defense export controls (ITAR)
  • Foreign direct investment review (CFIUS)
  • Foreign Corrupt Practices Act (FCPA)
  • Tariffs, trade and customs

Reid is a thought leader on cross-border business regulations. He lectures as an adjunct professor of law at the New College of the Humanities in London, at the Université Catholique de Lille in France and at Wake Forest University in the United States, where he teaches courses on the law of international business. Reid is also a member of Chatham House, the UK's Royal Institute of International Affairs.

Writing and commenting regularly on cross-border transactional regulations, Reid is called on by television news channels, international newspapers and trade publications to provide analysis on the latest trends. He is the lead author and editor of The CFIUS Book. In addition, Reid conducts seminars on regulatory updates to industry groups in the U.S., France, Belgium, Spain and the UK.

Reid is fluent in French.

In his free time, Reid enjoys playing ultimate frisbee and has competed in national and world championships.

Experience

Representative Experience:

U.S. Sanctions

  • Advises four of the five largest banks in Korea and two of the largest banks in the Republic of Georgia
  • Advised on completion of €500 million deal between EU security service provider and Iranian airport authorities for security services at Iranian airports in compliance with post-JCPOA sanctions
  • Advised Italian finance and insurance bank on compliance with U.S. sanctions on Iran, Sudan and Russia
  • Represented Nordic petrochemical company before the Department of Treasury and Department of Commerce with respect to ongoing projects in Iran caught in new U.S. regulations
  • Advised Swiss aircraft and transportation service company with respect to managing Russian clients
  • Investigated and defended Korean multinational bank in OFAC enforcement action related to Iranian accounts and obtained a decision of no criminal penalties
  • Counseled multinational engineering firm on pipeline project in joint venture with Russia
  • Designed compliance measures for satellite communications company to provide services to ships entering territorial waters of sanctioned countries
  • Advised on successful acquisition by non-U.S. company of Singapore entity with Iranian supply chain in compliance with applicable U.S. regulations
  • Performed compliance investigation for U.S. private equity company acquiring ownership of non-U.S. energy company with interests in Iran
  • Designed in-house compliance capabilities for U.S. investment services company for its global web-based offerings

White Collar Defense and Litigation

  • Defended U.S. multinational energy company in FCPA investigation by U.S. Justice Department (DOJ) and Securities and Exchange Commission (SEC) as well as foreign authorities 
  • Defended U.S. electronics distributor in enforcement action by U.S. Attorney's Office for Middle District of Florida resulting in civil disposition with no criminal charges
  • Defended software company in investigation of sales to Iran under U.S. sanctions and export control regulations
  • Led the internal investigation for a global bank into its OFAC sanctions compliance practices and defended against enforcement actions by DOJ, OFAC, SDNY and U.S. bank regulatory authorities
  • Advised on the defense of FCPA investigation of Fortune 100 U.S. agricultural products company related to bribery allegations on three continents

CFIUS

  • Represented French conglomerate on a €850 million strategic acquisition of a U.S. renewable energy company
  • Represented UK defense manufacturer in acquisition of California aerospace company in two-stage transaction delaying trigger of mandatory CFIUS declaration filing
  • Represented seller in auction sale of assets including real property proximate to U.S. Naval Base
  • Coordinated with Sheppard M&A team to provide prospective advice on the CFIUS risk of dozens of prospective deals pre- and post-FIRRMA
  • Represented French investors in acquisition of U.S. manufacturers of deep sea exploration and naval search and rescue equipment
  • Represented seller in sale to Indian computing equipment manufacturer and obtained CFIUS clearance on behalf of both parties
  • Represented U.S. entity in CFIUS submission in connection with sale to non-U.S. investment fund of critical infrastructure assets

Tariffs, Trade and Customs

  • Appeared with clients before U.S. Trade Representative committee on the imposition of Section 301 tariffs to present their cases for exemption from the tariffs
  • Advised several U.S. manufacturers on submitting comments on and requesting exemptions from the imposition of Section 301 tariffs on products and components from China
  • Successfully represented a U.S. manufacturer to the Korean Customs Service and obtained preferential treatment in Korea for that company’s products under the Korea U.S. Free Trade Agreement
  • Represented U.S. and Canadian petroleum shippers, natural gas shippers and pipelines in discussions with U.S. Customs and U.S. Census on regulatory interpretations

Foreign Corrupt Practices Act

  • Represented U.S. energy company in a multi-national anti-bribery and FCPA investigation conducted in coordination between U.S. and Ghanaian authorities
  • Defended U.S. energy company in FCPA investigation by U.S. Justice Department (DOJ) and Securities and Exchange Commission (SEC) 
  • Conducted internal investigation of FCPA red flag reports related to sales by U.S. oil field equipment manufacturer from its agent in South America
  • Designed FCPA and Chinese anti-corruption compliance program for the Chinese operations of U.S. Fortune 100 electronics company
  • Advised on internal FCPA investigation of Fortune 100 U.S. agricultural products company related to bribery allegations on three continents
  • Counseled non-U.S. automotive company on developing and implementing compliance program and training

Export Controls

  • Applied for and obtained one of the first export licenses under revised sanctions regulations that permitted a U.S. company to send good to Cuba to support a clean-water initiative in that country
  • Completed a company-wide ITAR compliance audit for the U.S. facilities of a global materials manufacturer and obtained a closed matter with no penalty or further action from The Directorate of Defense Trade Controls (DDTC)
  • Executed an ITAR review for a U.S. aerospace and defense manufacturer, integrating the compliance policies of two merged companies and reporting to regulators on the same
  • Completed a review of EAR control compliance for a second-market microchip distributor pursuant to an FBI subpoena and negotiated closure of the investigation with significant reduction in penalties as a result of compliance improvements and cooperation
  • Represented major U.S. consulting firm in internal investigation relating to the inadvertent export of controlled technical data
  • Counseled Fortune 100 aerospace company concerning civilian and military export control matters, including controls relating to encryption and composites
  • Represented non-U.S. multinational chemical manufacturer in obtaining licenses for the export of controlled chemicals for medical research
  • Advised multiple U.S. research universities on technology and deemed export issues related to non-U.S. campuses, students and faculty
  • Represented global automotive company establish and deploy export compliance processes, agreement language and training to U.S. and non-U.S. personnel
  • Defended U.S. electronics distributor in enforcement action by U.S. Attorney's Office for Middle District of Florida resulting in civil disposition with no criminal charges
  • Represented Non-U.S. multinational manufacturer obtain licenses under ITAR for sharing controlled technical data to produce protective equipment for the U.S. military

Litigation and Other

  • Prepared a petition for certiori to the U.S. Supreme Court for a suit to protect the civil rights of immigrant detainees
  • Defended the District of Columbia in a civil suit against 32 DCPD officers for damages related to the service of a warrant on a murder suspect
  • Defended the District of Columbia in a civil suit against doctors at public hospitals who had performed free clinic care for patients underserved areas
  • Served as judicial clerk for the U.S. District Court for the Western District of Virginia

Pro Bono

  • Represented the widows of U.S. veterans in efforts to obtain benefits from the U.S. Veterans Administration
Credentials
Education

J.D., Wake Forest University, 2007, Fletcher Scholar, Editorial Staff, Wake Forest Law Review

B.A., The College of William & Mary, 2002, cum laude

Admissions

Commonwealth of Virginia

District of Columbia

U.S. District Court for the Western District of Virginia

U.S. District Court for the Eastern District of Virginia

U.S. Bankruptcy Court for the Eastern District of Virginia

U.S. Court of Appeals for the Fourth Circuit

Brussels, Belgium (B List)

Honors
  • "Ones to Watch," Best Lawyers, 2024
  • Top Advisor, Foreign Investment Watch, 2021
  • Leading Lawyer - International Trade, Chambers Global, 2021-2026
  • Washington D.C. Rising Star, Super Lawyers, 2013-2017
Foreign Investment Watch 2021
Memberships
  • Chair, Young Lawyers Division, International Section, American Bar Association
  • Member, Barreau de Bruxelles: Liste B – The Belgian bar for international lawyers practicing in Brussels
  • Appointed Vice-Chair, Law Student, LLM and New Lawyer Outreach Committee, International Law Section, American Bar Association, August 2012 - August 2013
  • Member, Europe Committee, International Law Section, American Bar Association
  • Member, International Practice Section, Virginia State Bar Association
Thought Leadership
  • "The New Containment: Technological Perimeters and Global Divides," US Trade Controls Compliance in Europe Conference, March 20, 2024
  • Co-Presenter, "Fundamental Challenges: Trade Compliance in University and Research Setting," WorldECR, November 18, 2021
  • Co-Presenter, "Establish Your U.S. Compliance System: A Strategic View from China and the United States,” China Intellectual Property Magazine, October 21, 2021
  • "Briefing: Key Changes in EU AML and US Sanction Regimes," Bird & Bird Program on Anti-Money Laundering and U.S. Sanctions, London, September, 2018
  • "Foreign Corrupt Practices Act," In-House Counsel Forum, Seoul, November, 2016
  • "Inside Washington: Law, Development and Diplomacy," ABA-UNDP International Legal Resource Center (ILRC), July 24, 2013
  • Panelist, "ITAR and EAR Compliance Review and Investigations: Conducting Internal Audits and Determining Whether to Disclose Potential Violations to Mitigate Penalties," Strafford Webinar, June 26, 2013
  • Panel Chair and Moderator, "Navigation without Maps: The Young Lawyer and the New Industry of International Anti-Bribery Compliance and Investigation," ABA International Fall Meeting, October, 2012
  • "Pathways to International Law," ABA Section of International Law
  • Panelist, George Washington Law School, March 10, 2011
  • Panelist, Catholic University, Columbus School of Law, October 18, 2011
  • Panelist, University of Baltimore School of Law, November 3, 2011
  • Panelist, International Law Student Association-Jessup Competition Finals Conference, March 30, 2012
  • Panelist, ABA International Section Spring Meeting, April 17, 2012
  • Panelist, ABA International Legal Education Summit, October 19, 2013

Television Commentary:

Books:

  • Editor and Lead Author, Foreign Direct Investment Controls - A Global Perspective, WorldECR, December 19, 2022
  • Author, World Encryption Controls, WorldECR, March 1, 2021
  • Editor and Lead Author, The CFIUS Book: Second Edition, WorldECR, May 1, 2020
  • Editor and Lead Author, The CFIUS Book, WorldECR, December 1, 2018