Carlos concentrates his practice in international and domestic transportation law, admiralty, regulatory maritime law, international commercial transactional law, transportation litigation and export licensing and compliance matters. He is also involved with transport issues that are affected by U.S. Customs and Border Protection and the Transportation Security Administration.
To ensure regulatory export compliance, Carlos coordinates global and U.S. acquisitions and mergers of multinational companies. He has deep experience with issues involving the Directorate Defense Trade Controls (Department of State) related to the International Traffic in Arms Regulations and with the Export Administration Regulations of the Department of Commerce. Carlos regularly deals with regulatory licensing issues, including assisting clients in licensing, registration and voluntary disclosures when required. He works with the Office of Foreign Assets Control on sanctioned country issues, including those related to Iran, Syria, Sudan, North Korea, Burma and others. He is involved in assisting clients in implementing compliance programs and establishing standard operating procedures to minimize risk with regard to export compliance matters. He has provided counseling to clients on “deemed export” issues in the context of foreign nationals visiting or working in the U.S. to minimize possible violations of the export compliance regulations. Carlos also counsels clients on exposure to violations arising from goods being re-exported.
In addition to drafting and negotiating service contracts with ocean steamship lines, Carlos represents shipyard and other interests before the Maritime Administration, the Military Sealift Command, the Department of Defense and other federal agencies. He provides advice to U.S. domiciled multinationals with regard to obtaining facility and staff security clearances from the Department of Defense for handling classified defense articles and on countering issues with the Foreign Ownership, Control or Influence program. Carlos advises and assists global logistics firms in negotiating and implementing global distribution and warehousing agreements in the U.S. and abroad.
Carlos advises U.S. logistics companies with regard to the Foreign Corrupt Practices Act and the Civil Reserve Air Fleet program.
Carlos has been involved with commercial development in China since the late 1970s, before diplomatic relations were established. He also frequently lectures before various international transportation industry associations. He is a liaison between shippers, shippers’ associations, transportation intermediaries, shipyards, Congress and government agencies.
Before joining the firm, Carlos was with Rodriguez O'Donnell in Washington, D.C. He was a U.S. Navy officer (1965-1968) and an investigator and trial attorney with the Federal Maritime Commission (1971-1977) before entering private practice.