Overview
Daniel E. Goren is an international trade attorney in Holland & Knight's Stamford office. Mr. Goren focuses his practice on a broad range of clients such as cutting-edge emerging technology companies, billion-dollar electronics manufacturers and Fortune 50 aerospace and defense contractors.
As an international trade lawyer, Mr. Goren advises clients on compliance with U.S. export controls such as the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), U.S. economic sanctions regulations administered by the Office of Foreign Assets Control (OFAC), and regulations governing the Committee on Foreign Investment in the United States (CFIUS).
Mr. Goren has conducted hundreds of internal investigations into potential violations of U.S. export and trade sanctions controls, and he has extensive experience preparing voluntary disclosures and designing and implementing responsive and pragmatic corrective actions.
Mr. Goren advises clients on navigating CFIUS regulations, including CFIUS filing requirements triggered by foreign investment in U.S. businesses. This includes mergers and acquisitions (M&A) due diligence, preparation of CFIUS filings and complex analysis to identify critical technologies, covered investment-critical infrastructure and controls related to sensitive personal data of U.S. citizens.
As a member of the Society for International Affairs (SIA), Mr. Goren served on the task force to rewrite SIA's Voluntary Disclosure Handbook, a guide broadly used by companies across the country. He also helps clients self-classify or prepare Commodity Jurisdiction (CJ) and Commodity Classification Automated Tracking System (CCATS) requests to determine the classification of their products under U.S. export law, including in some of the more difficult areas such as encryption controls.
In addition to his legal practice, Mr. Goren co-teaches a course on International Trade Compliance at the University of Connecticut School of Law, one of only a few law school classes of its kind nationwide.
Prior to joining Holland & Knight, Mr. Goren was an attorney at a law firm in Connecticut.
While in law school, Mr. Goren was the editor-in-chief of the Connecticut Law Review.
Before becoming an attorney, Mr. Goren spent nearly 10 years as a reporter for several newspapers in Massachusetts and Connecticut.
Representative Experience
- Counseled a global manufacturer of advanced driver-assistance systems regarding its compliance with U.S. export and economic sanctions regulations, including detailed analysis of its products under the de minimis and foreign direct product rules, as well as navigating difficult questions related to new restrictions on Russia and China
- Advised a global communications device manufacturer on export controls and economic sanctions, including resolving issues created by the listing of one of the client's primary suppliers as a specially designated national (SDN)
- Provided guidance to a global aerospace company related to export controls that apply to essential engine software source code
- Advised a leading software and service provider to the semiconductor industry on export and sanctions controls, including as related to Entity List fabrication facilities in China
- Counseled an emerging manufacturer of powdered additive metal and energy materials on export and sanctions controls and helped the company successfully navigate submissions with the Committee on Foreign Investment in the United States (CFIUS) related to $35 million in foreign investment
- Advised clients related to restrictions on service to aircraft owned, controlled or leased by Russian nationals in the wake of Russia's invasion of Ukraine, including successfully obtaining authorization from the U.S. Department of Commerce for a Russian-owned aircraft to receive service involving items subject to U.S. export controls
- Conducted financial sanctions self-assessment and provided advice on U.S. financial sanctions to a leading management consultancy firm
- Counseled parties on the Commerce Department's Entity List to help them remain compliant with the designation's stringent restrictions as they worked to be delisted
- Completed extensive secondments to in-house teams of a major U.S. aerospace and defense contractor with responsibility for large-scale investigations into potential violations of U.S. export regulations, drafting voluntary disclosures and implementing corrective actions
- Advised a Fortune 50 aerospace and defense subsidiary in developing a process for export classification of encryption commodities and software and its use of the related export license exceptions
- Engaged by a Fortune 50 subsidiary to investigate and disclose to the Office of Foreign Assets Control (OFAC) exports of commercial software to Iran, resulting in no penalty for client
- Pivotal member of a team that conducted an extensive internal investigation into potential OFAC violations for one of the world's largest banks
- Advised numerous foreign companies on U.S. export controls, including one of the world's largest providers of cryptanalytic devices, a major provider of state-of-the-art application security and static code analysis software, and a leading military electronics company
- Crafted successful export classification submissions for a major foreign defense contractor and a major manufacturer of global electrical components, culminating in advantageous lower levels of control
- Guided software companies through the process of determining the U.S. export classification of software with cryptographic and cryptanalytic functionality
- Advised leading data collection and analytics companies on export and sanctions controls on software that gathers information from public social media and the dark web
- Advised numerous clients on the application of the Commerce Department's de minimis rule to foreign-origin products incorporating U.S.-origin goods, impact of the foreign-made direct product rules on goods made from U.S.-origin technology or software, and application of the Bureau of Industry and Security's (BIS) second foreign incorporation principle
- Served as a key member of a team working with the U.S. Department of State to monitor and oversee an international aerospace company operating under a consent agreement, conducting site visits and analyzing the company's compliance program
Credentials
- University of Connecticut School of Law, J.D., with high honors
- Columbia University Graduate School of Journalism, M.S.
- Dartmouth College, B.A., Government, cum laude
- Connecticut
- U.S. District Court for the District of Connecticut
- Lexology Index: Trade & Customs, 2024; Transport: Unmanned Aircraft Systems, 2021-2022
- Highly Commended, WorldECR, 2018
- Exceptional Achievement in Outstanding Scholarship, University of Connecticut School of Law, 2011
- CALI Excellence for the Future Awards, Contracts, Lawyering Process (twice), Moot Court, Statutory Interpretation, and Law and Interpretation, University of Connecticut School of Law, 2008-2011
- Allstate Foundation Award for Excellence, Torts and Contracts, University of Connecticut School of Law, 2011