Rebekah M. Jones is counsel in the international trade practice based in Singapore. Her clients include companies based in Asia and the Asia operations of large multinational corporations.

Practice & Background

Ms. Jones counsels clients with global operations on U.S. law and policy affecting international trade and business, including export control laws, sanction programs, anticorruption laws, anti-money laundering (AML) laws, antiboycott regulations and foreign investment in the United States. She advises companies on regulatory compliance matters and various compliance-related issues, such as conducting internal investigations and responding to government investigations; drafting voluntary disclosures and negotiating settlements with government regulators; developing and implementing compliance policies and procedures; and developing, implementing and conducting training related to compliance programs.

Ms. Jones has significant experience advising clients in a variety of industries, including aerospace and defense, high technology, engineering services, logistics and freight forwarding, as well as private equity funds and other investors, on matters involving:

  • defense trade controls (ITAR) administered by the U.S. Department of State (DDTC)
  • dual-use export controls (EAR) and antiboycott regulations administered by the U.S. Department of Commerce (BIS, OAC, Census)
  • anticorruption laws and programs, including the U.S. Foreign Corrupt Practices Act (FCPA), enforced by the U.S. Department of Justice and the U.S. Securities and Exchange Commission; the U.K. Bribery Act, enforced by the U.K. Serious Fraud Office; and World Bank guidelines, enforced by the Integrity Vice Presidency
  • U.S. sanctions programs administered by the Office of Foreign Assets Control (OFAC).

Her work also involves counseling clients with international investment decisions and transactions by conducting due diligence reviews of trade control, sanctions, anticorruption and AML issues; addressing related concerns that arise; and preparing risk-factor assessments and disclosures. She also advises clients with regard to U.S. national security-based foreign investment restrictions administered by the Committee on Foreign Investment in the United States (CFIUS).

Prior to joining Akin Gump Strauss Hauer & Feld LLP, Ms. Jones received her J.D. with honors from The George Washington University Law School, where she was a member of The George Washington International Law Review.

Representative Matters

Ms. Jones’s representative matters include:

Anticorruption

  • representation of a non-U.S. energy and infrastructure company in connection with a World Bank investigation relating to a contract for a project in an African nation
  • advising a U.S.-based hypermarket on industry practices involved in direct sourcing of products from foreign suppliers, including analysis of wide-ranging issues, such as anticorruption, customs and import compliance, consumer protection, FDA regulations, labor and employment standards, and corporate social responsibility
  • developing global, U.S. and U.K. anticorruption, export controls and sanctions compliance handbooks and providing training for a pharmaceutical manufacturer headquartered in India
  • representing a multinational beverage company on internal investigations regarding joint ventures and subsidiaries located in Pakistan, India and Bangladesh
  • conducting due diligence for a private equity firm concerning anticorruption matters for investments in India, China and Malaysia, and evaluation of compliance policies
  • representing a global real estate private equity firm in establishing FCPA compliance procedures and providing training related to FCPA compliance
  • drafting and implementing an FCPA compliance program for a construction and logistics firm with global operations
  • developing and providing FCPA compliance training to a sovereign wealth fund focused on investments in various industries, such as aerospace, infrastructure and real estate
  • drafting contractual terms for a U.S. manufacturer in relation to the engagement of agents and distributors in the Middle East and Africa.

Export Controls

  • assisting companies in addressing export control regulatory issues related to extraterritorial U.S. laws, as well as laws of other countries (e.g., Australia, India, Japan)
  • advising a Taiwanese semiconductor company on U.S. export control issues involving encryption and integrated circuits
  • advising international aerospace and defense industry clients on a broad spectrum of ongoing export controls issues, such as:
    • developing and implementing programs and strategies for compliance with the ITAR, EAR and OFAC regulations across varied global operations, including design and development, marketing, sales, supply chain management and aftermarket services
    • leading numerous internal reviews, audits and investigations related to compliance with the ITAR, EAR and OFAC regulations
    • managing the preparation and filing of voluntary disclosures to DDTC and BIS
    • drafting license and agreement applications and other submissions to relevant agencies
    • analyzing jurisdiction and classification of products and technology
    • preparing clients for U.S. government audits
  • drafting and conducting training programs on various export compliance issues, including jurisdiction and classification, license and agreement application, and management of export compliance obligations for both U.S. and non-U.S. companies
  • advising a European airline in a BIS investigation involving alleged EAR violations and drafting related policy for compliance with EAR
  • analyzing the jurisdiction and classification of encrypted products for a U.S. high technology company and subsequently leading the related investigation and filing of a voluntary disclosure to BIS
  • developing a jurisdiction and classification program for a global automotive supplier for compliance with ITAR and EAR regulations.

Economic Sanctions

  • providing a global electronics company based in Korea with an assessment of risks and exposure under U.S. sanctions and export controls laws
  • obtaining a novel license from OFAC on behalf of a logistics and freight forwarding company authorizing the company to follow alternative procedures for disposing of blocked goods under OFAC sanctions programs
  • analyzing the U.S. sanctions implications on a Korea-U.S. joint venture with operations in Iran
  • providing training to various clients related to the implications of U.S. sanctions on non-U.S. parties and/or joint ventures.

Transactions/CFIUS

  • conducting due diligence and advising aerospace and defense clients on international trade-related issues during mergers, acquisitions and divestitures
  • analyzing potential CFIUS implications and successfully managing CFIUS review of various mergers and divestitures in the aerospace and defense industry
  • conducting anticorruption, AML, trade controls and sanctions diligence for U.S. private equity funds related to various investments in India, China, Malaysia, Australia and other Asia-Pacific locations
  • analyzing jurisdiction and classification of products and technology on behalf of a world-renowned U.S. specialty hospital in connection with a transaction to set up a research facility with a Chinese investor and advising on CFIUS implications of the transaction.

Speaking Engagements

  • “ITAR Enforcement,” Export Compliance Training Institute Seminar Series, U.S. Export Controls on Non-US Transactions, May 23, 2017, Singapore
  • “Managing Legal and Reputational Risk in Global Business Transactions: Lessons and Trends in International Trade Enforcement and Corporate Social Responsibility,” American Chamber of Commerce, February 4, 2016, Singapore
  • U.S. Department of State’s Export Control and Related Border Security Program Seminar, September 2, 2015 (Singapore)
  • “Enforcement and Investigation: Understanding Trends and Responding to Non-Compliance,” Defense Exports Asia Pacific, SMI Group, May 11, 2015 (Singapore)
  • “ITAR Enforcement,” US ITAR Defense Trade Controls Seminar, Export Compliance Training Institute, March 13, 2015 (Singapore)
  • “Managing U.S. Export Requirements as a Non-U.S. Entity: Understanding and Mitigating Compliance Risks,” Joint Industry Outreach Seminar on Strategic Trade Management, jointly hosted by Singapore Customs, the U.S. Bureau of Industry and Security and the U.S. Export Control and Related Border Security, December 4, 2014 (Singapore)
  • “EAR and OFAC Enforcement,” EAR/OFAC Commercial Export Controls & Embargoes, Export Compliance Training Institute, March 11, 2014 (Singapore).