David Glynn

David Glynn has recognized expertise in conducting detailed internal investigations and audits related to export controls, trade sanctions, and Customs laws.

Working with clients in the development, drafting, and implementation of compliance programs in various areas of federal regulatory law, he utilizes his extensive experience in export management systems and import compliance programs to help his clients achieve their goals.

With significant experience in federal regulation of international business with a focus in export controls, trade sanctions, and Customs compliance matters, David represents international and domestic companies in complex civil and criminal investigations involving the Departments of State, Commerce, Treasury, Justice, and Customs and Border Protection.

He also drafts license applications, commodity jurisdiction requests, technical assistance agreements, registration statements, encryption item review requests, export and trade sanctions voluntary disclosures, Customs Ruling Requests, Customs Prior Disclosures, Customs seizure responses, Customs penalty petitions, duty preference assessments, and performs export/trade sanctions and import audits.

David assists clients with Committee on Foreign Investment in the United States (CFIUS) counseling, transaction reviews, filings, and National Security Agreement mitigation plans.

David has studied law in the emerging markets of China and Brazil, and has completed additional training in International Marketing, and is a licensed U.S. Customs broker.

Client Results

Representative Matters

Over twenty-five voluntary and directed disclosures and other investigations before the Departments of State, Commerce, and Treasury.
Conducted a Department of State directed audit pursuant to a Consent Agreement of a U.S. integrated circuit manufacturer.
Conducted two Department of State directed audits of 21 U.S. laboratory and manufacturing locations of European aircraft parts producer.
A publicly traded, multi-national service firm with respect to the export of ITAR controlled data and services related to nuclear weapons testing facilities.
A publicly traded global communications equipment company internal investigation of past violations related to valuation and commodity classification and preparation of a comprehensive voluntary self-disclosure to U.S. Customs and Border Protection.
A multinational manufacturer of motion and fluid control technologies investigation and Prior Disclosure to U.S. Customs and Border Protection related to valuation, classification, and origin errors.
A world leader in essential oils and wellness solutions with respect to investigation of importation of Iranian origin products and disclosure to U.S. Customs and Border Protection and the Office of Foreign Assets Control.
A large sporting goods manufacturer with respect to an Antidumping investigation of forged hatchets from China and disclosure to U.S. Customs and Border Protection.
A medical products importer investigation of commodity classification and visa/quota compliance, preparation, and submission of a comprehensive Prior Disclosure to U.S. Customs and Border Protection.
A large on-line travel services company with respect to Office of Foreign Asset Control (OFAC) sanctions.
A sports equipment manufacturer with respect to unlicensed exports of controlled carbon fiber material to China.
A United Kingdom satellite manufacturer with respect to State Department licensing for reexport of ITAR-controlled items.
A sports outerwear company with respect to a Customs and Border Protection Focused Assessment audit.
Multi-national corporations in developing compliance programs and implementation of on-line training in various areas of federal regulatory law.
A major U.S. chemical manufacturer investigation of NAFTA origin certificate inquiries and validation methodologies used for certification.

Media Mentions

News

Publications

November 1, 2024
SEIA Standard Available for Public Comment through November 4 Import/Export Update
July 26, 2024
Guidance on Extension of Statute of Limitations for Civil and Criminal Violations of Sanctions Authorities OFAC Update
April 23, 2024
CFIUS Proposed Rule Aims to Strengthen Penalty and Enforcement Measures CFIUS Update
December 2020
Custom Law Committee 2020 Year in Review
American Bar Association
March 25, 2020
Beware of Export Control Compliance in COVID-19 Teleworking Environment Holland & Hart News Update
03/02/2020
Foreign Currency Policy: A New Duty Risk for U.S. Importers? Holland & Hart International Compliance Blog
March 2, 2020
Foreign Currency Policy: A New Duty Risk for U.S. Importers? International Compliance Blog
Do you know where your supply chain was last night?
ColoradoBiz
1/12/2011
New Export Control Certification Requirement for Employment Visas Holland & Hart News Alert
6/13/2006
Treasury Department Quintuples Maximum Civil Penalty for Trade Sanction Violations
Summer 2007
Customs Law
The International Lawyer, Vol. 41, Number 2, p. 185

Speaking Engagements and Events

March 1, 2024
Commodity Jurisdiction 2024 ICPA Annual Conference
April 26, 2023
Import Compliance Concepts
World Trade Day Denver
March 2, 2022
The Russia – Ukraine Conflict: Managing Risk in Uncertain Times Holland & Hart Webinar
02/28/2022
HTSUS Classification - a GRI Review
International Compliance Professionals Association (ICPA) Conference 2022
October 2020
International Traffic in Arms Regulations (ITAR) Training
World Trade Center Denver
May 2020
Import Compliance Concepts
World Trade Center Denver
January 2017
ITAR and the EAR: US Trade Controls Compliance in Europe, Pre-Conference Workshop
C5 Group, Co-Presenter with Candace Goforth, London, UK
April 5, 2016
ITAR Compliance
Rocky Mountain World Trade Center Institute, Denver, CO
March 2016
Import Compliance
Rocky Mountain World Trade Center Institute, Denver, CO
March 2016
Import Compliance
Rocky Mountain World Trade Center Institute, Denver, CO
December 2015
OFAC: U.S. Treasury Department Sanctions and Regulatory Requirements
U.S. Commercial Service and World Trade Center Utah, Salt Lake City, UT
March 2015
Export Licensing
International Compliance Professionals (ICPA) Annual Conference, Fort Worth, TX
September 16, 2014
Hot Topics for Export Compliance Professionals
U.S. Commercial Service and World Trade Center Utah, Salt Lake City, UT
September 2014
Academia and Related Export Controls
U.S. Commercial Service and World Trade Center Utah, Salt Lake City, UT
June 2014
Trade Sanctions, Commercial, Dual-use and Defense Article Export Controls
Holland & Hart Seminar, Boise, ID
April 2014
ITAR Training
Rocky Mountain World Trade Center Institute, Denver, CO
November 2013
Workshops for Export Compliance Professionals
U.S. Commercial Service and World Trade Center Utah, Salt Lake City, UT
October 2013
U.S. Trade Sanctions: Challenges for Compliance
International Compliance Professionals Association (ICPA) Fall Conference, Co-Presenter, Dallas, TX
March 2013
Writing a TCP
International Compliance Professionals Association (ICPA) Annual Conference, Honolulu, HI
October 2012
Investigations, Disclosures and Dealing with Mandated Corrective Actions in the Aftermath of Violations
Rocky Mountain Export Compliance and Enforcement Forum, Denver, CO
July 2012
Export Law – Regulatory Compliance
World Trade Center Denver China Business Series – Doing Business with China, Denver, CO
June 2012
ITAR Training
Rocky Mountain World Trade Center Institute, Full Day ITAR Program, Denver, CO
June 2012
U.S. Export Controls Overview for Contracting Professionals
National Contract Management Association Acquisition Training, Pikes Peak Chapter, Colorado Springs, CO
April 2012
Directorate of Defense Trade Controls (DDTC) Audits and Tips for Compliance Ready Programs
24th Annual Export Control Coordinators Association, Idaho National Laboratory, Idaho Falls, ID
April 2012
U.S. Export Controls Overview for Contracting Professionals
National Contract Management Association Meeting, Southeast Idaho Chapter, Idaho Falls, ID
March 2012
Import Violations, Investigations and Disclosures: What, When and How
International Compliance Professionals Association (ICPA) Annual Conference, Co-Presenter with Andrew Gray, Atlanta, GA
December 6, 2011
International Traffic in Arms Regulations: Avoiding Mishaps, Delays and Inadvertent Violations When Exporting from the U.S.
Utah Governor's Office of Economic Development, Salt Lake City, UT
2011
Federal Regulation of Technical Information: Practical Considerations for Sharing Information in UAS Research & Development
Panel member, International Conference on Unmanned Aircraft Systems, Denver, CO
March 22, 2011
Self-Disclosures, Audits, and Internal Investigations
International Compliance Professionals Association Compliance Conference, Co-presenter, Phoenix, AZ
April 2010
Best Practices for Global Sourcing and Regulatory Compliance in a New Era
Moderator and Program Chair, Spring Meeting, American Bar Association, New York, NY
December 2009
The Fundamentals of ITAR Compliance: The International Traffic in Arms Regulation Demystified
C5, ITAR Compliance in Europe, Munich, Germany
November 2009
Third Party Risks: Exchanging ITAR Data and Services
American Institute of Engineers Defense Export Controls conference, Las Vegas, NV
Principles of Importing: Importer Responsibilities, Reasonable Care Standard/Due Diligence, Fines, Penalties & Forfeitures, Customs Audit/Self-Review Programs, C-TPAT, and Country of Origin Rules
Rocky Mountain World Trade Center Institute Presentation also given on March 4 & October 8, 2008, March 20 & October 9, 2007, May 25 & October 17, 2006, Denver, CO
September 2008 & December 2008
Hot Topics: Changes & Trends at the State Department, Brokering, Voluntary Disclosures, Third-Country/Dual Nationals, D-Trade, & Merger & Acquisition Due Diligence and much more
International Trade in Arms Regulations seminar, Salt Lake City, UT, also given in Colorado Springs, CO
May 8, 2008
Intermediate International Traffic in Arms Regulations (ITAR): Doing Business in an ITAR World
Rocky Mountain World Trade Center Institute, Denver, CO
March 2008
What's So Reasonable About Reasonable Care
International Compliance Professionals Association (ICPA) Annual Conference, San Antonio, TX
Import Regulatory / Case Update
Import Compliance & Enforcement Seminar, Denver, CO
October 11, 2007
Introduction to International Traffic in Arms Regulations (ITAR)
Rocky Mountain World Trade Center Institute, Denver, CO
October 4, 2007
Keeping it Real - Protecting Your Brand from Trademark Counterfeiting
Outdoor Industry Association Annual Rendezvous Conference, Vancouver, WA
Overview of ITAR Controls for Foreign Companies
Consulate General of Canada aerospace industry seminar, Colorado Springs, CO
International Due Diligence & U.S. Import/Export Controls
Colorado Bar Association 8th Annual Business Law Institute, Vail, CO
The Impact of Export/Import Control Laws on International Business
NALS Region 8 conference, Denver, CO
U.S. Import Controls: Mergers & Acquisitions Due Diligence
Holland & Hart LLP, Denver, CO
U.S. Import Controls: Outsourcing Issues
Holland & Hart LLP, Denver, CO
Common Mistakes to Avoid When Exporting From the United States
German American Chamber of Commerce, Colorado Chapter, Denver, CO
International Legal Essentials: Government Regulation & Trade Law
Rocky Mountain World Trade Center Institute, Denver, CO
2005
International Trade Legal Issues: U.S. Export Controls
University of Colorado-Denver and University of Denver graduate business schools
International Supply Chain Security: U.S. C-TPAT Program Overview
Colorado Springs Office of International Affairs, Colorado Springs, CO

Professional and Civic Affiliations

World Trade Center Denver, Member, Board of Directors
American Bar Association, Member
International Law Customs Committee, Co-Chair, 2020 - present
Colorado Bar Association, Member
Denver Bar Association, Member
New York Bar Association, Member
Colorado GLBT Bar Association, Member

Recognition

World Trade Center Denver, Outstanding Service Award, 2022
Lexology and International Law Office, Client Choice Award, International Trade in Colorado, 2018

Practice Areas

Industries

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