
Overview
Larry is the Chair of Dorsey’s National Security Law Group and is head of the firm’s Seattle office. Clients ranging from small emerging companies or family-owned businesses to Fortune 500 public corporations and international professional associations trust Larry to advise them on ever-evolving national security law and international trade matters. Larry has worked across countless industry sectors and has developed particular expertise in aerospace and defense, mining, technology (including AI/ML), biotech, financial services, higher education, and manufacturing. He helps clients understand various complicated U.S. regulatory schemes so that they can comply in a cost-effective manner to avoid the reputational damage and the monetary, criminal, and other penalties that can occur when those regulations are violated. As a former appointed member of the U.S. State Department’s Defense Trade Advisory Group (DTAG), Larry has built important connections with U.S. Government and industry leaders, which further bolsters his ability to provide practical compliance insight to his clients.
Larry advises clients on compliance matters related to U.S. export controls and national security law regularly representing clients before:
- the Committee on Foreign Investment in the United States (CFIUS) on regulatory issues associated with foreign investment in the United States;
- the U.S. Defense Department’s Defense Counterintelligence and Security Agency (DCSA) on compliance with the National Industrial Security Program Operating Manual (NISPOM) and with plans to mitigate foreign ownership, control and influence (FOCI);
- the U.S. Commerce Department on matters involving the Export Administration Regulations (EAR);
- the U.S. State Department on matters involving the International Traffic in Arms Regulations (ITAR);
- the U.S. Treasury Department on matters involving the economic sanctions administered by the Office of Foreign Assets Control (OFAC);
- the U.S. Energy Department and the Nuclear Regulatory Commission on matters involving energy and nuclear exports; and
- the U.S. Justice Department and Securities and Exchange Commission on matters involving the Foreign Corrupt Practices Act (FCPA).
Larry helps clients build and refine compliance programs, train employees, classify products for export purposes, apply for export licenses and classification requests from the U.S. Government and structure internal safeguards for dealing with classified federal government information. When something goes wrong, he helps companies internally investigate potential violations of the law and strategize how best to disclose violations to the U.S. Government. Larry also helps clients in building international relationships with various third parties by drafting and negotiating various commercial contracts. Before those relationships are even built, he helps clients craft due diligence programs and assists with vetting of potential foreign partners to ensure that the risks of violations of export control and international business ethics are low.
When the business stakes are highest and a client is involved in transactional activity, Larry provides national security and international trade due diligence. He also helps foreign buyers and U.S. targets navigate important regulatory issues associated with foreign investment in the United States when U.S. national security is implicated through the transaction.
Education & Admissions
University of Notre Dame Law School (J.D., 2003), Dean’s List; Dean’s Award for Outstanding Academic Achievement in Trial Advocacy; Legislative Reform Editor, Journal of Legislation; Treasurer, Student Bar Association
University of Notre Dame (M.Ed., 2000), Highest Honors; Distinguished Portfolio
University of Notre Dame (B.A., 1998), Dean’s List, Class of 1998 Service Award
Admissions
- Washington
- California
Experience
Client Achievements
- 德汇代表亿腾医药就其收购礼来旗下两款著名抗生素产品希刻劳®和稳可信®以及位于苏州的希刻劳生产工厂提供全面法律服务 Dorsey Represents Eddingpharm in Acquisition of Eli Lilly’s Rights in China for Ceclor® and Vancocin® as well as its Ceclor Manufacturing Facility in Suzhou
- Beijing-based Ninebot completes strategic acquisition of Segway
- Tekmira and OnCore merge to create global company focused on HBV treatment
Representative Matters
Foreign Investment
Buy Side Representations
- Represented Manara Minerals in a deal to acquire 10% of Vale Base Metals Limited, the holding entity of Vale SA’s energy transition metals business.
- Represented a German buyer in connection with its acquisition of a U.S. oil and gas technology company.
- Represented a Saudi Arabian company with its successful investment in a U.S. technology company.
- Represented a Chinese company in its acquisition of a U.S. aerospace manufacturing company and negotiated an extensive mitigation agreement with the U.S. Defense Department in connection with the acquisition.
- Represented a Canadian company with U.S. holdings engaged in the mining and production of uranium in the review and investigation by CFIUS in connection with the sale of a majority equity interest to a Russian state-owned entity.
- Represented Canadian fuel and petroleum distributor in its acquisition of U.S. fuel distributor with network of fuel service stations in review by CFIUS.
- Represented Canadian utility infrastructure equipment and services company in its acquisition of assets of privately held utility services company in review by CFIUS.
- Represented a Chinese leading short-distance personal transportation vehicle maker based in Beijing in its acquisition of the world’s leading provider of personal electric transportation known for its two-wheeled, self-balancing electric vehicles in review by CFIUS.
- Represented several Top 10 real estate conglomerates from China in CFIUS analysis regarding their real estate transactions in various U.S. states.
- Represented a robotics company in Z-Park of Beijing in post-acquisition CFIUS analysis and compliance.
- Negotiated a critical amendment to a letter of assurance with the U.S. Defense Department on behalf of a Chinese-owned company and its U.S.-based energy assets.
- Represented several China-based family offices in transaction-based CFIUS analysis for their investments in the United States.
- Represented Singaporean company in CFIUS filings in connection with its acquisition of multiple U.S. businesses.
- Advised Chinese AI company regarding potential implications of CFIUS regulations on its business.
- Advised multiple companies of varying nationalities in connection with their acquisition of real estate in the United States in connection with greenfield investments.
Sell Side Representations
- Negotiated a first of its kind mitigation agreement on behalf of a U.S. energy storage company in connection with investment by a Chinese company.
- Represented a U.S. semiconductor manufacturer in connection with the sale to a Chinese investment company.
- Conducted internal investigation for a U.S. company suspected of breaching its mitigation agreement with DOD.
- Represented a European founder in his sale of his U.S. aerospace business and negotiated a complex mitigation agreement with the U.S. Department of Defense.
- Provided counsel to multiple U.S. companies that received requests for information (RFI) from CFIUS related to “non-notified” investments.
- Represented U.S. designer and producer of 4G and 5G networking equipment in its sale to a conglomerate from the United Arab Emirates.
- Represented a U.S. provider of cybersecurity solutions in its sale of various sensitive assets to a French owned defense contractor.
- Represented a U.S. enterprise data management provider in its acquisition by a Japanese holding conglomerate and negotiated a mitigation agreement with the U.S. Justice Department in connection with the acquisition.
- Represented publicly held global provider of broadband communications network infrastructure products and related services in its acquisition by a French diversified manufacturing and services holding company.
- Represented a Canada-based mining company on the regulatory aspects involved in the disposition of a 29% interest of stock that was held by a Chinese-controlled Canada-based company under an order by CFIUS.
- Represented U.S. space operations and ground network services provider in its acquisition by Swedish state-owned space systems company in review and investigation by CFIUS and assisted the U.S. company in navigating on of the first of its kind mitigation agreements with the U.S. Defense Department.
- Represented one of the largest credit card payment network companies in the world in its CFIUS analysis, compliance, and training.
- Represented a series of venture capital funds and their growth stage portfolio companies in their transaction-based CFIUS analysis and post-closing CFIUS work.
- Represented U.S. defense contractor in the sale of its business, which included ITAR work, to U.K. company.
Economic Sanctions
- Advised non-U.S. clients on the extra-territorial effects of sanctions in jurisdictions outside the United States and potential consequences of such sanctions on those clients’ future U.S. business activities.
- Assisted a U.S. public company with investigating and voluntarily self-disclosing apparent violations of the Iranian sanctions by its Chinese affiliate and successfully negotiated a “cautionary letter” (i.e., no financial penalty) with the U.S. Government in connection with the apparent violations.
- Engaged by a Singaporean public company to respond to a subpoena from OFAC alleging that the company caused a major U.S. financial institution to repeatedly violate U.S. sanctions laws.
- Gained precedent-setting rulings under the various sanctions programs for international engineering societies and other publishers to provide exempt “information and information materials” to persons in sanctioned countries and to engage in the collective authorship and publishing of such works.
- Obtained OFAC licenses for multiple clients to transact business in Iran, Cuba, and Sudan in a wide variety of circumstances and across multiple industries.
- Advised on cases of investigation and disclosure by international banks of suspected funds transfers involving either sanctioned countries or SDNs.
- Advised e-payment processing company on sanctions screening matters with focus on avoiding violations of Ukraine-related sanctions applicable to Russian/Crimean customers of the client.
- Provided training to a Norwegian bank regarding impact of U.S. economic sanctions and export control laws on the bank’s operations.
- Provided ongoing quarterly reports to the Board and management of one of the five largest U.S. financial institutions regarding the sanctions enforcement matter that our group handled on behalf of a company owned 49% by that financial institution.
- Regularly work with a U.S. underwriter to help it understand U.S. economic sanctions and export control implications in certain deals financed by its EU and Asian operations.
- Regularly assist underwriters in negotiating export control and economic sanctions representations, warranties, and covenants in various financing and related documents.
- Managed the investigation and resolution of the largest case of Cuban travel embargo violations, involving over 44,000 persons, in the history of the U.S. Cuban travel embargo.
- Worked with the Chinese office of a U.S. public company to provide tailored economic sanctions training to Chinese employees about the impact of those sanctions on foreign persons.
- Provided specialized economic sanctions and export control training to the Hong Kong operations of a major U.S. financial institution.
- Prepared stock exchange required memoranda for numerous clients on U.S. economic sanctions and export controls compliance in connection with initial public offerings on an Hong Kong Stock Exchange.
- Assisted numerous Fortune 500 companies navigate Russian sanctions and, in some cases, wind-up Russian operations.
- Conducted internal investigation for large state university suspected of violations of Iran sanctions.
Export Controls
- Advised a leading San Diego based biotech research institution on export control matters.
- Led export control due diligence in connection with hundreds of M&A transactions.
- Led the internal investigation for a Los Angeles-based aerospace supplier with design facilities in China in assessing apparent violations of the EAR, disclosing those violations to the OEE, and obtaining a cautionary letter (i.e., no penalty).
- After disclosure of potential EAR violations to the OEE, developed critical fixes to the export control compliance program of a Los Angeles-based aerospace supplier with design facilities in China.
- Advised a drone company on its response to an OEE subpoena resulting in no further action.
- Led the internal investigation of a major public university to assess potential export control violations.
- Negotiated settlement of antiboycott violations on behalf of a family-owned U.S. defense contractor.
- Advised U.S. artificial intelligence company on export transactions involving Chinese business partner.
- Serves as trusted advisor to numerous state and private universities on compliance with export controls.
- Supported U.S.-based automotive software and technology company navigate changing export controls impacting industry.
- Obtained export licenses for an aerospace company to share sensitive technology with non-U.S. persons in the United States.
- Counseled U.S. companies on due diligence for export sales opportunities to ensure compliance with trade restrictions imposed on Belarus and Russia.
News & Resources
Articles
News & Press Mentions
Events & Speaking Engagements
Select Presentations
- Co-Presenter, “Cracking the CFIUS Code: Challenges to IP Rights in CFIUS Reviews,” New York City Bar Webinar, May 14, 2020
- Presenter, “End-Use and End-User Due Diligence,” 11th Annual Pacific NW Export Control Conference, July 31, 2019
- Presenter, “Import and Export Factors Impacting Northwest Businesses,” Pacific Northwest Defense Coalition Briefing, May 9, 2019
- Co-Presenter, “Practical Issues in CFIUS and Export Controls,” Berkeley Center for Law & Technology, April 10, 2019
- Presenter, “Structuring Your Classification Approach: Determining Jurisdiction,” PNDC’s Export Compliance Summit: EAR & ITAR, December 7-8, 2017
- Presenter, “The Impact of Regulatory Changes on the M&A Market: Focus on Economic Sanctions, Export Control Laws, FCPA, and CFIUS,” 11th Annual M&A Seminar (The Seminar Group), November 1, 2017
- Presenter, Webinar “Introduction to the U.S. Export Administration Regulations (EAR),” PNDC Webinar, October 12, 2017
- Presenter, “US Economic Sanctions and Russia, Doing Business in Today’s Russia: Practical Considerations for Minnesota Companies,” Sept. 26, 2017
- Presenter, “Export Control Compliance in the Oil & Gas Industry,” Strafford Webinar (CLE), Sept. 12, 2017
- Presenter, “Legal Due Diligence for Your Exporting Business,” Pacific Northwest Export Controls Conference (PNECC), Seattle University School of Law, July 27, 2017
- Presenter, “International Trade Compliance,” 9th Annual Northwest Export Conference: Exporting and the New Administration – Compliance and Opportunities, Export Finance Assistance Center of Washington (EFACW), July 25, 2017
- Co-presenter, “Section 734.13(b) of the EAR: How to Satisfy the ‘Deemed Export’ Rule, Foreign National Screening and Form I-129 Requirements amid Conflicting Foreign Privacy and Human Rights Laws,” ACI’s EAR Boot Camp on May 23-24, 2017
- Co-presenter, “Labor & Employment Lawyers: What they should all know about U.S. Export Controls and Sanctions” Dorsey Video Training Program, April 28, 2017
- Presenter, “U.S. Economic Sanctions and Non-U.S. Companies,” BA-HR Programme: Anti-Corruption, Compliance and Trade Sanctions Seminar, January 19, 2017
- Presenter, “Practical Tips For Responding to Export Control Concerns at all Stages of your Company’s Growth,” 2016 Export Controls Conference: Evolving Controls for a Changing World, Seattle, Washington, July 28, 2016
- Co-presenter, “Structuring Your USML Classification Approach: Understanding the “Order of Review” Post Reform, Determining ITAR Jurisdiction, and Submitting a Commodity Jurisdiction Request,” ACI’s 14th ITAR Boot Camp, Chicago, Illinois, May 25, 2016
- Co-presenter, “U.S. Economic Sanctions Programs and Recent Changes Impacting What Banks Can Do in Cuba and Iran,” Dorsey Bank Counsel Roundtable, April 27, 2016
- Presenter, “Overview of U.S. Economic Sanctions and their Impact on Exporters,” Pacific Northwest Defense Coalition (PNDC) – Defense Export Compliance & Opportunities Conference, Seattle, Washington, April 21, 2016
- Presenter, “Important Developments on US Iranian Economic Sanctions,” ABA Sanctions Year in Review, Washington, DC, February 2, 2016
- Presenter, “Enforcement Cases and What to do if Something Has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, December 9-10, 2015
- Co-presenter, “International Traffic in Arms Regulations (ITAR) Update,” PNDC Lunch & Learn, Seattle, Washington, September 30, 2015
- Presenter, “Export Violations in the Post-ECR Environment,” 2015 Export Controls Conference, Seattle, Washington, July 29-30, 2015
- Co-presenter, “Navigating Ukraine-Related Sanctions: Meeting the Latest U.S. and E.U. Sanctions,” Strafford CLE, June 9, 2015
- Presenter, “U.S. National Security Laws and Their Impact on Classified Contractors,” DSS CI & FBI Strategic Counterintelligence Partnership with Defense Industrial Base - 2nd Annual Conference, Anchorage, Alaska, May 7, 2015
- Co-presenter, “When and How to Submit a CJ Instead of Conducting a Self-Determination: How to Prepare the Request and What to Do after Receiving a DDTC and DTSA Determination,” ACI’s 13th ITAR Boot Camp, San Diego, California, February 24-25, 2015
- Presenter, “Russia/Ukraine-related sanctions,” ABA Sanctions YIR Event, Washington, DC, January 29, 2015
- Presenter, “Impact of U.S. Export Control Laws on Immigration Filings,” Dorsey Breakfast Briefing, January 27, 2015
- Presenter, “2014 Enforcement Matters and What to do When Something Has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, January 8, 2015
- Panelist, “What BIS and DDTC Expect from Your Technology Control Plan: How to Incorporate and Implement New IT Management, Security and Training Procedures that will Impress the Agencies,” American Conference Institute’s 8th Forum on International Technology Transfers & Deemed Export Compliance, San Francisco, California, September 2014
- Co-panelist, “OFAC Ukraine-Related Sanctions: Overcoming Compliance Challenges, Meeting Evolving U.S. and EU Sanctions,” Strafford CLE, September 2014
- Presenter, “Internal Investigations and Voluntary Self-Disclosures,” Microsoft Export Controls 2014 Conference, Redmond, Washington, July 10, 2014
- Co-presenter, “Ensuring Your Company’s Success Through Compliance with the U.S. Foreign Corrupt Practices Act,” PNDC ITAR Summit, Portland, Oregon, January 30, 2014
- Presenter, “Recent Enforcement Cases and What to Do if Something has Gone Wrong,” PNDC ITAR Summit, Portland, Oregon, January 30, 2014
- Co-presenter, “Establishing & Maintaining an Effective Export Controls Compliance Program,” PNDC ITAR Summit, Portland, Oregon, January 29, 2014
- Presenter, “2013 U.S Export Controls Year in Review,” ABA Section of Internationals Law, Washington, DC, January 2014
- Panel Moderator, “Stay Private or Take Our A&D Company Public?” Orange County Aerospace and Defense Forum, Costa Mesa, California, November 2013
- Panelist, “Export Control Reform and Industry,” ICE Seattle Export Control Seminar, October 2013
- Presenter, “An Overview of Export Controls under the U.S. Department of Commerce,” ICE Seattle Export Control Seminar, October 2013
- Presenter, “Recent FCPA Developments and Conducting Internal Investigations,” WSBA International Law Section CLE, Seattle, Washington, September 2013
- Panel Moderator, “Is Your A&D Company Part of the $500B Yearly CYBER Loss?” Orange County Aerospace and Defense Forum, Costa Mesa, California, August 2013
- Presenter, “Recent Developments with CFIUS,” Dorsey U CLE Program, July 2013
- Presenter, “Nuts and Bolts of Export Controls: Dealing with the Regulations,” Pacific Northwest Defense Coalition and U.S. Commercial Service, Portland Oregon, January 2013
- Presenter, “Overview of the Foreign Corrupt Practices Act,” Pacific Northwest Defense Coalition and U.S. Commercial Service, Portland Oregon, January 2013
- Presenter, “How U.S. Export Control and Related Laws and Regulations May Change during the Next Four Years,” Orange County Aerospace and Defense Forum, Costa Mesa, California, December 2012
- Presenter, “The Impact of Deemed Exports in the University and Research Institute Setting,” Export Council of Oregon and U.S. Commercial Service, Portland, Oregon, November 2011 and December 2012
- Presenter, “Fundamentals of U.S. Export Control Laws,” WSBA International Law Section CLE, Seattle, Washington, September 2012
- Presenter, “U.S. Export Controls,” Montana World Trade Center, Bozeman, Montana, May 2012
- Presenter, “Overview of the U.S. Foreign Corrupt Practices Act,” U.S. Commercial Service and Pacific Northwest Defense Coalition, Portland, Oregon, January 2012
- Presenter, "Legal Considerations for International Business," Montana World Trade Center ExporTech, Missoula, Montana, April 2011
- Presenter, "Basic Considerations for Selling and Sourcing in International Agreements," International Trade Alliance New-to-Export Seminar, Seattle, Washington and Tukwila, Washington, March, August and September 2011
- Presenter, “Foreign Investments and Acquisitions in the United States: Dealing with CFIUS,” Dorsey U CLE Program, February 2011
Industries & Practices
Banking & Financial Institutions
Explore This Practice View client achievements related to this practice View resources related to this practiceEnergy & Natural Resources
Explore This Practice View client achievements related to this practice View resources related to this practiceFood, Beverage & Agribusiness
Explore This Practice View client achievements related to this practice View resources related to this practiceHealthcare & Life Sciences
Explore This Practice View client achievements related to this practice View resources related to this practiceGovernment Solutions & Investigations
Explore This Practice View client achievements related to this practice View resources related to this practiceGovernment Contracts Counseling & Litigation
Explore This Practice View client achievements related to this practice View resources related to this practiceDevelopment & Infrastructure
Explore This Practice View client achievements related to this practice View resources related to this practiceAntitrust & Competition Law
Explore This Practice View client achievements related to this practice View resources related to this practiceEnvironmental, Social, Governance (ESG)
Explore This Practice View client achievements related to this practice View resources related to this practiceHigher Education & Academic Research Institutions
Explore This Practice View client achievements related to this practice View resources related to this practiceTransactional Risk Insurance
Explore This Practice View client achievements related to this practice View resources related to this practice- Antitrust & Competition Law
- Aviation
- Banking & Financial Institutions
- China
- Development & Infrastructure
- Electric Power
- Energy & Natural Resources
- Environmental, Social, Governance (ESG)
- FinTech
- Food, Beverage & Agribusiness
- Government Contracts Counseling & Litigation
- Government Solutions & Investigations
- Healthcare & Life Sciences
- Higher Education & Academic Research Institutions
- Intellectual Property
- International Trade
- Mergers & Acquisitions
- Mining
- National Security Law
- Oil & Gas
- Sustainability
- Technology
- Technology Commerce
- Transactional Risk Insurance
Professional & Civic
Professional Achievements
- Washington State China Relations Council, Board Member, 2025
- Defense Trade Advisory Group (DTAG) for the U.S. Department of State, Former Appointed Member
- Export Controls and Economic Sanctions Committee of the ABA Section of International Law, Steering Group Member and “Year in Review” Co-Editor
- Washington District Export Council, Member
- Pacific Northwest Defense Coalition (PNDC), Member
Community Involvement
- Treehouse, Board Member, 2013 to Present
- Communities Rise (fka Wayfind), Board Member, 2012 to 2018
- Washington State Bar Association, International Practice Section, Member
- St. Joseph School, Former School Commission Member
Accolades
- Named one of “America’s Leading Business Lawyers” by Chambers USA ( International Trade: CFIUS Experts), 2023-2024
- Contributed more than 50 Challenge pro bono hours, 2021-2022
- Dorsey & Whitney – Scales of Justice Team Award (The World Ventilator Foundation), 2021
- Dorsey & Whitney – Scales of Justice Team Award (Promise of Justice Initiative’s Unanimous Juries Project), 2022
- Appointed to the Defense Trade Advisory Group (DTAG)
- Recognized as a "40 Under 40" honoree by the Puget Sound Business Journal, 2013
- Listed as a “Rising Star” by Washington Super Lawyers, 2013-2015
