Right-Sized Compliance: Scaling Your Company’s Screening Program

Ian Robinson is a Senior Director in the Export Controls, Sanctions, and Trade practice at FTI Consulting, and he is based in New York, NY. Ian has more than six years of experience in international trade matters with a primary focus on export controls compliance.

Ian has worked as a close advisor to the global trade compliance teams of some of the world’s largest semiconductor manufacturing companies. In recent years, his expertise has been focused on business process design and systems implementation for automated global trade management solutions, with a particular emphasis on restricted party screening. He recently assisted with the comprehensive overhaul of a company’s restricted party screening platform, working to design, test, and integrate more than 10 disparate systems spanning hundreds of business stakeholders across various departments, with a combined total of more than 1.5 million records in the screening database. Working as part of a full-time secondment, he helped introduce practical business process solutions for the management of screening hits and adjudication. Separately, he recently helped advise another major semiconductor manufacturer with the vendor selection process of a new global trade management system.

Ian has also led onsite visits and transaction testing workstreams for three separate ITAR consent agreement audits, completing hundreds of interviews at dozens of global sites. Ian has also previously provided substantial project management and on-the-ground support for a leading multinational telecommunications equipment and technology company undergoing a multi-year government mandated audit by a U.S. monitor. He led interviews with company executives, conducted process walkthroughs, and reviewed presentations for the U.S. monitor interviews. In addition, he assisted the company with building out their export compliance program across 300+ subsidiaries.

Ian has assisted global organizations in assessing their compliance programs and has recommended opportunities to enhance their programs. He has assisted clients in assessing various export control areas, including export classification, license, and export authorization reviews, maintaining effective export compliance manuals, preparing for government-directed audits, executing consent agreement audits, and performing accurate restricted party screening. Ian has worked with multinational clients with operations across North America, Europe, Asia, Africa, and Central and South America.

Prior to FTI Consulting, Ian was a Senior Associate at a Big 4 firm focusing on export controls and sanctions compliance. Ian is a licensed CPA in the state of New York and received his Bachelor and Master of Accountancy degrees from the George Washington University School of Business.

Eric J. Rudolph’s work focuses on compliance with economic sanctions and U.S. export controls. An attorney by experience and training, Mr. Rudolph has led, managed and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa and Asia); internal investigations; economic and trade sanctions, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR) counseling; jurisdiction and classification analyses; and training efforts. In his practice, Mr. Rudolph focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities.

Additionally, Mr. Rudolph has significant experience in working with companies operating under government-appointed compliance monitors/officials, including serving as part of the monitor team in a sanctions and export controls case involving criminal and civil settlements with the Department of Justice (DOJ), Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS). Mr. Rudolph has led audit teams for consent agreements with the Department of State for ITAR violations, and also assisted the sanctions compliance leadership at the New York branch of one of the world’s largest banks, operating under the oversight of a monitor imposed by NYDFS, with the design and implementation of enhancements to its OFAC compliance program.

Mr. Rudolph’s experience with sanctions matters includes advising clients on compliance with various programs administered by OFAC; review of compliance programs; review and recommendations on screening and due diligence procedures; investigation of potential violations; advising on sanctions matters in the context of M&A due diligence and integration; and assisting with voluntary self-disclosures and remedial measures. Mr. Rudolph’s support of M&A activities includes providing expertise in CFIUS matters, such as leading export classification reviews to inform notice requirements, and overall assistance with export control compliance and other post- closing matters in support of mitigation agreement requirements.

Previously, Mr. Rudolph worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm before joining the Big 4. Mr. Rudolph also worked for 15 years as an in- house lawyer, including acting as a General Counsel, with public manufacturing companies in various industries and has substantial experience in advising Boards and global executive leadership and management on all aspects of compliance.

In addition to sanctions and export controls compliance, Mr. Rudolph also has experience with anti-bribery matters, including policies and procedures, investigations, voluntary disclosures and remediation, and in U.S. Customs Service matters. Mr. Rudolph previously served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACTPN), the U.S. government’s senior trade advisory panel and, in that capacity, participated in the drafting of ACTPN reports to the President, the Congress, and the Office of the U.S. Trade Representative on several free trade agreements.

Prior to entering in-house legal practice, Mr. Rudolph investigated and litigated fraud cases as a government securities regulator, working with various state and federal law enforcement and regulatory agencies, including on high-profile cases involving Ponzi schemes that resulted in criminal convictions and abusive broker-dealer sales practices.

Ivy Llena has over 14 years of experience in the learning and development field, providing capacity-building and professional development programs for corporate and social service agencies in the US and the Philippines.

Before joining ACSS, she was a program director at a non-profit organization in the Philippines, where she co-designed and co-implemented economic empowerment programs and services for survivors of human trafficking and their families. Ivy also served at the Social Policy Institute at Washington University in St. Louis, where she led and contributed to inclusive economic growth initiatives.