Lu also routinely counsels clients on the Committee on Foreign Investment in the United States (CFIUS) regulations, anti-boycott laws, Withhold Release Orders (WROs), and anti-corruption laws including the Foreign Corrupt Practices Act (FCPA).
He provides clients with a variety of trade compliance services, such as: transaction-related due diligence; counseling on, and the preparation of, filings to CFIUS; determining the export classifications of products; advising on and preparing export license applications; providing advice and counsel on a wide range of sanctions questions; complying with, and challenging WROs and findings of forced labor by Customs and Border Protection (CBP); delivering compliance training; and helping clients design and implement tailored international trade compliance policies and procedures. In addition, Lu has conducted hundreds of internal investigations related to potential violations of international trade compliance regulations and has extensive experience drafting voluntary disclosures to relevant agencies. He has significant experience responding to inquiries and enforcement actions from government agencies.
Lu has first-hand knowledge of the challenges clients face when implementing international trade compliance programs, having served as Assistant General Counsel – Global Trade at Raytheon Technologies’ Collins Aerospace division, as well as its Pratt & Whitney division. Lu led an international trade compliance internal audit program, developing risk assessments and conducting numerous compliance audits related to sanctions and export control requirements. Prior to Raytheon Technologies, Lu practiced at an international law firm in Washington, D.C., and a Connecticut-based law firm where he focused on international trade compliance and investigations.