Profile
Kara Bombach is Chair of the firm’s Washington, D.C. International Trade Group. She assists companies and organizations to lawfully export goods, technology, and services around the globe, prioritizing practical, workable strategies for complex regulatory situations. Kara regularly advises on export control laws (EAR and ITAR), anti-boycott laws, and economic sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various entities, individuals, and countries (including Iran, Cuba and Russia). She also advises on anti-corruption and anti-bribery compliance and best practices under the U.S. Foreign Corrupt Practices Act (FCPA).
In cases of foreign investment that might raise national security concerns, Kara represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations. Kara works closely with GT colleagues around the world advising on cross-border deals that may trigger national security review in multiple jurisdictions. Kara similarly advises clients on the U.S. Outbound Investment Security Program (OISP) to be implemented by the U.S. Department of the Treasury commencing January 2025, which prohibits certain outbound investment and imposes reporting requirements on others.
Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury, and Defense. She has significant experience representing individuals and entities in export controls and economic sanctions licensing, enforcement, and delisting matters, and challenges to sanctions designations.
Kara is frequently sought out in exigent circumstances involving export control and sanctions crisis management, such as business disruptions caused by rapidly escalating sanctions laws and regulations, blocked property and asset freezes, and ransomware attacks involving potential sanctions compliance risks.
She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of trade compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and trade compliance investigations.
Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.
Capabilities
Experience
- Enhanced and implemented global anti-corruption compliance program of Fortune 50 company consistent with elements of "effective compliance program" under OECD and US DOJ guidelines, including country and region focused policies, procedures, and training.
- Designed and deployed Global Anticorruption Policy and implementing procedures for major multinational retailer.
- Conducted in-country risk assessments and compliance program enhancements for U.S. companies’ subsidiaries in South America, Europe, and Africa.
- Resolution of export controls enforcement matter for university client related to unauthorized exports of biological materials. Resolved the administrative subpoena investigation (Dept of Commerce, Bureau of Industry & Security, Office of Export Enforcement) with a NO ACTION LETTER, no civil penalties, and no finding of liability.
- Achieved removal of Chinese company from U.S. Department of Commerce, Bureau of Industry & Security’s Entity List.
- Served as outside counsel to The Boeing Company on export controls and economic sanctions matters.
- Represented Rafael Márquez, the most successful soccer player in Mexico’s history, in his successful delisting from the Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals (SDN), which spanned 5-years and included negotiations with various U.S. agencies, the Mexican government, and the U.S. consulate in Mexico.
- Achieved resolution of multi-agency, multi-year export violation matter for armed security service provider with no monetary or administrative penalties.
- Achieved resolution of multi-country OFAC economic sanctions violations disclosure matter, with no monetary or administrative penalties.
- Achieved OFAC delisting of entities designated on OFAC’s list of Specially Designated Nationals (SDNs).
- Delivered global economic sanctions compliance program enhancements for household brand name food and beverage manufacturer.
- Obtained time sensitive OFAC licenses for international relief organization operations globally.
- Served as outside export controls counsel to numerous U.S. and non-U.S. aerospace prime and sub tier contractors and suppliers across airframe, engine, avionics, landing, cargo, and weapons systems, civil and military variants and platforms.
- Served as outside export controls counsel for prime U.S. contractor on the NASA shuttle program and international space station, including development and maintenance of global ITAR Technical Assistance Agreement and EAR/ITAR technology control plans for supply, payload, operations, and training involving foreign suppliers and/or partners.
- Served as outside export controls counsel for commercial space flight operations in ITAR technical assistance agreements and licensing matters related to launch service providers, and development and collaboration with foreign partners.
- Represented the asset management unit of Seoul, Korea-based Mirae Asset Financial Group before the Committee on Foreign Investment in the United States (CFIUS) in obtaining CFIUS clearance within the statutory minimum CFIUS 45-day review period for Mirae’s $5.8 billion acquisition of a 15-hotel portfolio in the United States from Anbang Insurance Group Co--the single-highest price tag for an overseas alternative investment by a Korean company. The luxury hotels include JW Marriott Essex House New York, The Ritz-Carlton Half Moon Bay, Montage Laguna Beach, Four Seasons Silicon Valley, Hotel Fairmont Scottsdale Princess, Four Seasons Arizona, Four Seasons Resort and Residences Jackson Hole, InterContinental Chicago, InterContinental Miami, and The Westin St. Francis San Francisco.
- Represented BioTelemetry, Inc. before the Committee on Foreign Investment in the United States in its pending $2.8 billion acquisition by Royal Philips N.V.
- Represented Canon Inc. before the Committee on Foreign Investment in the United States for its acquisition of Molecular Imprints, Inc.
- Represented AB Volvo before the Committee on Foreign Investment in the United States for the sale of its aerospace business to GKN plc for £700m.
- Advised TTM Technologies, Inc. in acquisition of Meadville Holdings, Ltd. printed circuit board business (total transaction value of approximately US$900 million).
- Negotiated Special Security Agreement (SSA) with U.S. Department of Defense on behalf of U.S. company acquired by foreign investor.
- Prepared, notified and negotiated approval by CFIUS on behalf of U.S. engineering services firm acquired by a UK company.
- Advised Goldman Sachs International on tender offer for 100% of shares in Polish real estate developer, ROBYG S.A.
- Advised Rentokil Initial plc in its acquisition of The Steritech Group, Inc. for $425 million.
- Advised Exactech, Inc. in its sale to private equity fund TPG Capital for $640 million.
- Intern, United Nations International Atomic Energy Agency Headquarters, Vienna, Austria, 1995-1996
Recognition & Leadership
- Team Member, a Law360 "Real Estate Practice Group of the Year," 2023
- Selected, Euromoney, "Women in Business Law Awards Americas - International Trade Lawyer of the Year," 2022
- Listed, Latin Lawyer, "Latin Lawyer 250 - Practice Recognition: Anti-Corruption Investigations and Compliance," 2020-2022 and 2024-2025
- Team Member, Global M&A Network’sAmericas M&A Atlas Awards, “Latam Deal of the Year” for Quinto Andar acquires Navent Group, 2023
- Team Member, National Law Journal, “Washington, D.C. Litigation Department of the Year - White Collar Defense & Special Investigations,” 2022
- Listed, Financier Worldwide, “Power Players: International Trade & Sanctions – Distinguished Advisors,” 2021
- Co-Chair, Cuba Practice, Chambers Latin America Guide, Corporate/Commercial: International Firms, (Band 3), 2018
- Team Member, "Corporate & Finance - International Counsel in Latin America (Florida-Based)," Chambers Latin America Awards, 2017
- Listed, Super Lawyers magazine, Washington, D.C. Super Lawyers, "Rising Star," 2013
- Member, Women’s White Collar Defense Association (WWCDA)
- Member, American Bar Association
- Steering Committee, Aerospace & Defense Industries Committee, Section of International Law and Practice (2014-2015)
- Member, National Security Committee
- Vice Chair, Export Controls and Economic Sanctions Committee, Section of International Law and Practice (2010-2011)
- Member, Association of Women in International Trade
- Member, District of Columbia Bar Association, International Law Section
- Member, International Bar Association, Anti-Corruption Interest Group and Women's Interest Group
- Member, Society for International Affairs
- Outside General Counsel to ALESA (American League for Export and Security Assistance – members include major multinational aerospace and defense companies)
Credentials
-
J.D., Boston University School of Law
- Concentration in International Law, with honors
- Managing Editor, Boston University International Law Journal
- Member, Phi Delta Phi Legal Honor Society
- A.B., Cornell University
- University of Vienna, Vienna, Austria
- District of Columbia
- Maryland
- French
- German
News, Insights & Events
Kara is a contributor to GT's E2 Law Blog 
and the Inside Business Immigration Blog