Aaron is a valuable resource as we evaluate investments in challenging or destabilized frontier markets. He helps us understand the landscape and risks and is anywhere in the world we need him to be.
—Salman Al-Rashid, Principal, Salmira Investment Fund

Aaron Hutman helps clients to engage in business, banking, investment and trade in the world’s most challenging markets, as well as to deal with the most sensitive technologies.

He focuses his practice on the intersection of international law, business and U.S. policy. With experience in over 60 countries on 5 continents, he understands the bigger picture of international business and the cultural nuances of different countries and regions. In Washington, DC, he has established authority in some of the most important legal areas affecting international trade and investment.

Representative Experience

Engaged for extended projects inside one of Europe’s largest aerospace and defense companies and separately one of the world’s largest social media and technology companies to develop compliance, export control, and sanctions capacities.

Advised multiple global energy companies on projects in challenging markets including Russia, Iran and Venezuela.

Conducted extensive internal investigation on Foreign Corrupt Practices Act and Brazilian anti-corruption law compliance for a Japanese company investing in the Brazilian shipbuilding industry.

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  • Anti-Money Laundering
    • Provided advice to multiple banks in Cyprus regarding improving their AML and sanctions compliance programs.
    • Provided advice to Middle Eastern free trade zone regarding improvement of their AML and sanctions compliance programs, including a review of best practices among "off-shore" and entity-forming jurisdictions in the wake of the Panama Papers revelations.
    • Advised cruise line with gambling operations on various aspects of U.S. anti-money laundering rules including casino AML programs, currency transfer, money services business, customer due diligence and other matters.
    • Helped one of the world’s largest financial institutions prepare AML compliance policies to address foreign currency controls and clients efforts to circumvent them.
  • Customs Compliance & Enforcement
    • Conducted internal reviews and prepared prior disclosures to Customs & Border Protection concerning compliance with an anti-dumping duty order.
    • Conducted investigation of AES and Foreign Trade Regulation compliance for government contractor and advised on corrections to records.
  • Cybersecurity and Data Privacy
    • Advised defense and commercial companies on cybersecurity attacks and guiding them on voluntary disclosures resulting from potential export control violations.
    • Advised multi-national telecommunications company on USA PATRIOT Act, online data security and Electronic Communications Privacy Act issues.
  • Economic Sanctions & Embargoes 
    • Advised global technology company on the complex sanctions and embargo rules for virtual reality software and hardware in Cuba, Iran, North Korea, Sudan and Syria.
    • Advised Japanese industrial and energy services companies on Russia and Iran sanctions matters.
    • Advised multiple Russian companies in the banking, energy and investment sectors on U.S. and EU sanctions and export controls.
    • Advised private equity fund with European portfolio affiliates proposing work with Iran; Provided compliance and strategic advice under U.S. and EU sanctions law.
    • Conducted internal investigation on printer manufacturer and its subsidiaries concerning Iran and Syria transactions, prepared disclosures to OFAC and BIS and responded to OFAC Administrative Subpoenas.
  • Export & Technology Transfer Controls
    • Led internal export compliance and technology control plan review and update for global 100 technology company.
    • Conducted extensive internal investigation related to alleged ITAR and EAR criminal and civil violations for a private security contractor and preparing comprehensive voluntary disclosures to DDTC, BIS and Census regarding exports of controlled items and provision of potential defense services.
    • Provided on-the-ground support for export control compliance internal audits in the U.S., UK and Saudi Arabia for multiple global defense and aerospace companies.
    • Advised on cutting edge applications for licenses, commodity jurisdiction (CJ) and CCATS with the DDTC and BIS.
  • Foreign Corrupt Practices Act (FCPA) and Global Anti-Corruption
    • Organized anti-corruption crisis management effort in Africa for Japanese company in response to report of potential bribery -- included travel to Ghana and Nigeria to instruct local counsel, local business leads and potential new agents and personnel. 
    • Conducted investigation in Mexico relating to complex anti-corruption and government-finance issues.
    • Conducted anticorruption training and prepared compliance materials for defense contractor active in the Middle East.
  • Frontier and Emerging Market Transactions
    • Advised international media company on entry into Myanmar market, including coordinating advice from local counsel on structuring, providing strategic advice on sanctions, anti-corruption, banking, tax, IP and AML challenges, and supporting acquisition of local Myanmar company.
    • Supported restructuring and fundraise in Hong Kong by U.S. private equity group for transportation company in Mongolia.
    • Advised investors on anti-corruption, sanctions and other compliance considerations in relation to an investment in a Sierra Leone transportation company.
    • Coordinated review of technology reseller and distribution agreement for U.S.-owned company in Saudi Arabia.
  • Regulation of Foreign Investment & National Security
    • Advised global hedge fund on how CFIUS review and U.S. policy could impact sensitive mergers and acquisitions.
    • Assessed compliance with DSS / NISPOM of target companies in support of an acquisition in the defense industry.
  • Trade Remedy Proceedings
    • Represented US fabricator in Department of Commerce administrative reviews and changed circumstances review related to an antidumping duty order's certification and reexport requirements involving impact of Japanese tsunami on reexport requirements.
    • Advised clients in CVD, NAFTA, and WTO elements relating to Softwood Lumber Products from Canada, one of the largest trade cases in history.
    • Represented uranium fabricator in Uranium from Russia (AD) and advised on compliance with the Russian Suspension Agreement.

Professional Highlights

Provided keynote address to the International Energy Forum's Industry Advisory Committee, speaking on how sanctions, cybersecurity and anti-corruption challenges impact the global energy landscape and its stability.

Founder and co-leader of annual conference on "Cybersecurity in the Global Energy Sector."

A sanctions and anti-money laundering authority with op-eds and frequent quotes with the Financial Times, Nikkei Asian Review and Reuters.

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  • Profiled in the 2017 WorldECR Awards which recognizes the achievements of export controls and sanctions professionals.


  • J.D., Harvard Law School, 2001

    B.S., Cornell University, 1997
    with honors


  • District of Columbia