A member of the Technology, Manufacturing & Transportation team, Carlos concentrates his practice in international and domestic transportation law. He skillfully navigates his maritime clients through the complexities of regulation and compliance in matters administered by U.S. Customs and Border Protection (CBP), the Transportation Security Administration (TSA) and other governing bodies. He also coordinates global and U.S. acquisitions and mergers of multinational companies. Throughout his career, Carlos has routinely handled complex informal and formal litigation including rulemaking matters before the Federal Maritime Commission.
Carlos has deep experience with International Traffic in Arms Regulations (ITAR) administered by the Directorate of Defense Trade Controls (DDTC) at the Department of State and with the Export Administration Regulations of the Department of Commerce. He frequently advises on regulatory licensing issues, including assisting clients in licensing, registration and voluntary disclosures when required. He works with the Office of Foreign Assets Control (OFAC) on sanctioned country issues, including those related to Iran, Syria, Sudan, North Korea, Burma and others.
Carlos is involved with structuring of agreements to establish off-shore distribution hubs for international distribution activities for retailers and multi-national logistics companies. He is also involved in establishing off-shore and domestic fulfillment facilities for B2C distribution for e-commerce transactions. He represents both retailers and multi-national logistics companies in this regard.
Assisting clients in implementing compliance and standard operating procedures, Carlos minimizes risk with regard to export compliance matters. He provides counseling to clients on “deemed export” issues in the context of foreign nationals visiting or working in the U.S. to avoid violations of the export compliance regulations. He 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 (DOD) 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 distribution and warehousing agreements in the U.S. and abroad.
Carlos counsels U.S. logistics companies with regard to the Foreign Corrupt Practices Act (FCPA) and the Civil Reserve Air Fleet (CRAF) program.
Carlos has been involved with commercial development in China since the late 1970s, before diplomatic relations were established. He also frequently delivers lectures to 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 (1964-1967) and an investigator and trial attorney with the Federal Maritime Commission (1971-1978) before entering private practice.