Curtis M. Dombek

Curt Dombek is a partner in the Government Contracts, Investigations and International Trade Practice Group. Curt divides his time between the firm's Brussels and Los Angeles offices.

Areas of Practice

Curt has practiced since 1983 in the field of international trade. He advises clients on international regulatory issues, including civilian and military export controls, trade sanctions and blocking orders, customs matters, the Foreign Corrupt Practices Act (FCPA), the USA Patriot Act, Free Trade Agreements, CFIUS reviews of foreign investment in the United States, the Conflict Minerals Rules of the SEC, the anti-boycott regulations and the U.S.-EU privacy safe harbor. He handles export control compliance and other international matters for multinationals in the telecommunications, computer hardware and software, aerospace and defense, energy, pharmaceutical, chemical, electronics and fashion and apparel industries.

Curt has designed international compliance programs and advised on complex questions of international compliance for companies with operations throughout the U.S. and the European Union as well as in Asia, Latin America and the Middle East. Assisting companies in complying with the detailed export controls on encryption and telecommunications technology is a significant part of his practice, as is the regulatory compliance relevant to outsourcing of design and production activities to India and China.

Curt has represented clients in many high-profile international trade cases. In Kuwait, he represented the Kuwait government in the preparation and submission of its Gulf War claims to the United Nations Compensation Commission. Curt has conducted many depositions and other investigative and discovery proceedings overseas and has represented domestic and foreign clients in ICC, LCIA and ad hoc arbitrations in Europe and the Far East as well as the U.S. He has addressed international conferences and published articles on a variety of international legal topics.

Honors

•Appointed by the Secretary of Commerce in 2012 to the Regulations and Procedures Technical Advisory Committee of the U.S. Department of Commerce, with responsibility for reviewing and advising the department on new export control regulations
•Appointed by the Secretary of Commerce in 2011 to the president's Export Council Subcommittee on Export Administration (PECSEA) as one of the industry representatives advising the administration on implementation of export control reform, working with the Undersecretary of Commerce, the Assistant Secretary for Export Administration and the Section Chiefs of the State Department Directorate of Defense Trade Control
•Chambers, International Trade Notable Practitioner
•Named by Los Angeles Magazine as one of the Southern California Super Lawyers in 2006-2012

Digital Media

Nota Bene Episode 22: Exploring the Impact of Foreign Investment Controls with Curt Dombek

Insights

Articles

•Co-authored chapter, U.S. Export Controls and the Cloud
Thomson Reuters Westlaw, 11.2013
•Compliance Issues with the New SEC Reporting and Disclosure Requirements Under the Iran Threat Reduction and Syria Human Rights Act of 2012
Bloomberg BNA, 12.12.2012
• Loosening Satellite Export Controls
Law360, 05.04.2012
• ‘Buy American’ And Solar Devices - DOD Clarification
Law360, 02.21.2012
• Early Steps Toward a Streamlined Export Control System
WorldECR, 12.22.2011
• The Proposed 2011 Reforms for Parts and Components and the New Definition of “Specially Designed”: A Divine Comedy or a Tragedy Indeed?
Practising Law Institute, 12.2011
• Taking Early Steps Toward Streamlined Export Control
Law360, 11.29.2011
• The Twilight Zone of International Arbitration, 21 Litigation 42, American Bar Association, 1995
• Implication of the Proposed Product Liability Fairness Act for Commercial Space Launches, Proceedings of the Annual International Bar Association Conference, Paris, 1995
• Harmonizing Allocations of Risk for Commercial Space Activities, Proceedings of the Inaugural Conference of the Inter-Pacific Bar Association, Tokyo, 1991
• Can Erie v. Tompkins Survive in Zero Gravity? The Case for a Federal Common Law of Space, Proceedings of the Annual International Bar Association Conference, New York, 1986

Corporate & Securities Law Blog Posts

• Appellate Court Issues Opinion on SEC's Conflict Minerals Rule, April 15, 2014
• Navigating the SEC's Recent Conflict Minerals Rules: Threading the Needle Through Complex Controls and Procedures and Complying with New Disclosure Requirements, September 21, 2012

Global Trade Law Blog Posts

• Modernizing NAFTA: The United States-Mexico-Canada Trade Agreement, January 17, 2020

• Comment Deadline Extended: Export Controls on Emerging Technologies, December 11, 2018
• The Little Regulation That Will Make a Big Change in How You Do Business: Department of Commerce to Establish New Export Controls on Emerging Technologies, November 19, 2018
• The New NAFTA: the United States-Mexico-Canada Agreement (USMCA), October 2, 2018
• Client Alert: Iran Sanctions Return, May 11, 2018
• 2018 EU Trade, Regulatory and Competition Trends, February 8, 2018
• Retrenchment on Cuban Sanctions; The Search for a Middle Ground, November 17, 2017
• Dinner Table Conversation: How an Offhand Comment May Signal a Shift in the Global Trade of Semiconductors, June 22, 2017
• The Undoing Project - Why NAFTA Can’t Be Undone, But Can Be Re-Done, January 31, 2017
• Top 12 EU Legal Developments to Watch in 2017, January 23, 2017
• The Baby and the Bathwater: The Department of Commerce’s Bureau of Industry and Security (BIS) Intrusion and Surveillance Software Export Licensing Proposal, July 17, 2015
• Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran? July 16, 2015
• New EU Rules on Disclosure of Ultimate Beneficial Owners, June 24, 2015
• U.S. Authorizes Targeted Sanctions Against Overseas Cyber Threats, April 3, 2015
• Add Importers to Those Facing Expanding Whistleblower Claims under the False Claims Act, March 5, 2015
• Mandatory Reporting of Foreign Direct Investments in the U.S., December 19, 2014
• EU Strengthens Economic Sanctions Against Russia, September 18, 2014
• New “Beast” Rules Lessen the Export Control Burden, May 7, 2013
• All Together Now: A New Joint Definition of 'Specially Designed',” July 11, 2012
• Opportunities in the New U.S.-Colombia Free Trade Agreement, June 7, 2012
• Proposed Easing of Satellite Export Controls Could Benefit U.S. Satellite Industry, May 1, 2012
• A Surprise Turn on the SEC’s Winding Road to the Dodd-Frank “Conflict Minerals” Rule, February 21, 2012
• EU’s New Sanctions Target Iran’s Oil Industry, January 30, 2012
• EU Imposes New Economic Sanctions on Syria, January 30, 2012

Government Contracts, Investigations & International Trade Blog Posts

• Add Importers to Those Facing Expanding Whistleblower Claims Under the False Claims Act, March 24, 2015
• Free(er?) Trade - US, EU and Canada Quibble Over Market Access and Domestic Preferences, August 15, 2013
• Buy American and Photovoltaic Devices - Interim Rule Issued by DoD, February 13, 2012
• Early Steps Toward a Streamlined Export Control System: Proposed Changes to the ITAR and EAR, November 16, 2011
• Proposed Rule Details Major Changes to U.S. Export Controls, August 4, 2011
• Proposed ITAR Rule To Relax ITAR Licensing For Components Incorporated Into Commercial Products, March 16, 2011
• New Sanctions Block Continuing Performance Of Libyan Government Contracts In Addition To Targeting Col. Qadhafi's Assets, March 16, 2011
• New Defense Authorization Act Imposes Buy American Act Mandate for Photovoltaics, January 18, 2011
• Amendment of Federal Sentencing Guidelines Calls for Updating of Compliance Policies, July 12, 2010
• New Encryption Export Rules Relax Regulatory Burden For Many End-Products But Also Raise Many New Questions, July 12, 2010
• BIS Issues New Export Controls on Millimeter Wave Security Equipment, Software and Technology, April 9, 2010
• Administration to Expedite Encryption Reviews and Amend ITAR Citizenship Definition, March 19, 2010
• Stay Tuned for Implementation of Ancillary Cryptography Changes Adopted by December 2009 Wassenaar Plenary Session, March 12, 2010

Latin American Blog Posts

• NAFTA Renegotiation Goes Live, May 19, 2017
• A Surge In Populism: Dangers To Transnational Trade In The Americas And Reasons For Hope, August 18, 2016
• New EU Rules on Disclosure of Ultimate Beneficial Owners, June 15, 2015
• OFAC Issues Cuban Asset Control Regulations focused on the U.S. Financial Sector, January 15, 2015
• Mexico Added to UK Open General License for Export Controls Following Wassenaar Accession, August 20, 2012
• Opportunities in the Upcoming U.S.-Colombia Free Trade Agreement, May 8, 2012
• Increasing Level of Seizures by U.S. Customs, July 29, 2011
• USCIS Makes Important Changes to I-129 Petition for Foreign Workers Effective December 23, December 17, 2010
• First Sale Rule Survives in the United States, October 22, 2010
• Increased Opportunities for Foreign Investment in Brazil Also Bring Increased Risk for FCPA Violations, March 25, 2010

Life Sciences Law Blog Posts

• Court of International Trade Ruling Provides Tariff Relief for Cell Culture Bioreactors, January 18, 2012

Media Mentions

•‘Buy American’ Drug Decision Opens Door to Foreign Supplies
Bloomberg Law, 02.18.2020
•2018 EU Competition & Regulatory Trends
Sheppard Mullin EU Competition Alert, 01.24.2018
•Zes Trump-lessen voor Belgische bedrijven
De Tijd, 02.03.2017
•Q&A With Sheppard Mullin's Curt Dombek
Law360, 03.08.2013
• Sheppard Mullin Lures Trade Guru From Bryan Cave
Law360, 01.05.2010

Speaking Engagements

•Faculty, American Conference Institute ITAR Bootcamp, San Diego, 2013 and 2017
•Faculty, “Defense Exports” SMi, Amsterdam 2012-2016, Rome, 2017
• Wassenaar Intrusion Software Regulations, Coalition for Responsible Cybersecurity and BSA: The Software Alliance, Brussels, 2016
•Faculty, American Conference Institute EAR Bootcamp, Chicago and San Diego 2013
•Faculty, American Conference Institute Export Controls Compliance, Washington 2013
•Faculty, “Coping with Export Controls,” Practising Law Institute, Washington, D.C., 2011, 2012 and 2013
•Class instructor, International Regulatory, Trade & Dispute Issues, China National Petroleum Council Beijing, 2010
•Panelist, Reexporting from China, China Summit on Export Controls Compliance, Beijing, 2010
•Lecturer, FCPA Workshop: Preventing Corruption, Sheppard Mullin's & Control Risks' joint conference, Los Angeles and Shanghai, 2010
• Legal Compliance in International Sales, San Diego, 2009
• Compliance with US and PRC Anti-Corruption Laws, Los Angeles and Shanghai, 2008
• Compliance with Encryption Export Controls, Los Angeles-based webinar, 2008
• The Perennial Problem of U.S. Encryption Controls, World Customs Organization Conference, Brussels, 2008
•“Global FCPA Compliance,” Shanghai, 2007
•“Encryption Export Compliance,” Seattle and St. Louis, 2007
•“Export Compliance in the Semiconductor Industry,” Chicago, 2006
• Foreign Corrupt Practices Act, joint program with KPMG and the U.S. DOJ, Los Angeles, 2005
•“Export Compliance in the Telecommunications Industry,” New York, Amsterdam, Denver, Frankfurt, Miami, New Delhi and Singapore, 2005
•“Avoiding Legal Pitfalls in International Sales and Marketing,” Phoenix, 2005
•“FCPA Compliance in the Energy Sector,” St. Louis, 2004
•“FCPA Compliance and Internal Audits,” New York, 2004
•“Export Compliance in the Telecommunications Sector,” Los Angeles, 2000, London, 2002, Dallas, 2002, Raleigh, 2003, and Boston, 2004
•Panelist, Are Global Antiterrorism Initiatives a Threat to International Commerce?” Annual Symposium of the Center for American and International Law, Dallas, 2004
•Presenter, “Aerospace and Defense: New Technologies and Commercialization Trends Raise New Legal Issues,” Federal Bar Association Conference, A Clear View to the Future of Technology, Los Angeles, 1999
•Presenter, “The State of the Law Governing Liability Among Launch Participants, Practitioners’ Forum of the European Centre for Space Law, Paris, 1993

Events

•NAFTA Now the USMCA: What’s New in the U.S., Canada, and Mexico Trade Deal
A Sheppard Mullin Webinar, 10.30.2018

•Do you have a license for Cybersecurity?
Cybersecurity, incident response, innovation and research under the new export control licensing rules, 06.08.2016

•Defense Exports 2015
Amsterdam, Netherlands, Fall 2015

•EU: Aerospace, Defense and Security Implications of the US Export Control Reform
Sheppard Mullin with Bird & Bird, Bird & Bird, London, 11.14.2013

•Lunch With Your Government Contracts Lawyer
Satellite Export Control Update, Sheppard Mullin Washington, D.C. office, 03.20.2013

•2011 Emerging Export Control and International Trade Law Issues: CLE Program and Cabernets of the World
Palo Alto Wine Networking Series, The Palo Alto Office, 04.21.2011

•Sheppard Mullin & Control Risks FCPA Workshop
Preventing Corruption: Good Business Practices = Good Business, 05.12.2010