Blog Post 09.10.26
Samantha Franks counsels global and U.S. companies complex international trade and regulatory matters, with a particular emphasis on economic sanctions, forced labor prevention and anti-corruption compliance. She helps clients build robust compliance programs, assess rapidly changing regulations and navigate complex markets, including jurisdictions such as Venezuela and Syria. Samantha also advises on export and import controls and government investigations and maintains a cross-cutting regulatory practice encompassing privacy, aviation and energy law.
Samantha has deep experience in international business and human rights, with a particular focus on forced labor prevention and human trafficking law. She has served as a subject matter expert on the forced labor prevention task force established by the Department of Health and Human Services’ Office of Trafficking in Persons, as well as an advisor to the University of Michigan Law School’s Business and Human Rights Lab, and provides pro bono counsel to a range of NGOs combating trafficking. Her global experience is complemented by her time as a Dean Acheson Legal Fellow at the Court of Justice of the European Union, where she clerked for Advocate General Nicholas Emiliou and studied the confluence of U.S. and EU law. Prior to law school, she studied international conflict prevention as a Fulbright postgraduate scholar in the United Kingdom.
Samantha is admitted in the District of Columbia and the Court of Appeals for the Second Circuit.
Representative Experience
- Advised European, Middle Eastern and Latin American airlines, aircraft and engine lessors in addressing global sanctions on Russia, insurance and litigation implications surrounding leased aircraft and engines, including BIS and OFAC licenses and unblocking funds, as well as OFAC- blocked-funds issues due to the involvement of sanctioned Russian financial institutions.
- Advise numerous clients on a wide range of tariff and trade measures introduced or intensified under the second Trump administration, including Section 232 and Section 301 tariffs, reciprocal tariff strategies and actions under the International Emergency Economic Powers Act (IEEPA).
- Represented the Joint Liquidators of Ireland’s largest-ever liquidation in navigating complex U.S. sanctions and export control compliance issues in connection with U.S. sanctions and export control licensing and U.S. insolvency proceedings.
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- Advise an American cybersecurity company on various sanctions, export controls and compliance issues, including conducting comprehensive risk assessments for sanctions and export controls under U.S., UK and EU programs and implementing an action plan to bolster the company's compliance program.
- Counsel the largest Cypriot bank on an ongoing basis regarding U.S. and sanctions, AML compliance matters and the interplay with rules in other jurisdictions, and assisted multiple Swiss financial institutions in conducting comprehensive on-site reviews and evaluations of their OFAC sanctions compliance programs.
- Represent a group of U.S. nuclear energy generators in ongoing trade matters before the Department of Commerce related to the Suspension Agreement on Uranium from Russia (RSA).
- Advise an independent liquidator of an international commercial bank on its billion-dollar resolution involving complex AML and sanctions issues, including Section 311 Special Measures under the USA PATRIOT Act, litigation with the U.S. Treasury Department and coordination with FinCEN, OFAC, global regulators and correspondent banks to facilitate asset recovery for victimized depositors.
Professional Highlights
- Clerk to Advocate General Nicholas Emiliou, Court of European Justice
- Let the Trees Speak: Nature’s Rights Under International Law, 42.3 Mich. J. Int’l Law (2021)
- Dangerous Trades: Article XXI’s Potential for Climate Security, 21 Wash. U. Global Stud. L. Rev. (2021)
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- Editor-in-Chief, Michigan Journal of International Law, Volume 42
- Honors and Awards
- Legal fellow at Auschwitz for the Study of Professional Ethics (2023)
- National Association of Women Lawyer’s Award (2021)
- Award for Exceptional Service to a Journal from Michigan Law (2021)
- Frederick Douglass Legal Fellow with the Human Trafficking Institute (2020–2021)
- Fulbright Postgraduate Scholar to the United Kingdom (2016–2017)
- Presentations
- 2020 American Society of International Law Midyear Forum
- 2021 Washington University School of Law International Symposium
- Other
- Board member of the Fulbright Association
- Co-host, Season One of Trafficking Matters, the Human Trafficking Institute’s podcast
- Alumni Advisory Board for the University of Missouri’s Kinder Institute
- Firm Publications
- “Specially Designated Nationals as Tenants: How Landlords Can Be Impacted by Sanctions against Russian Nationals,” March 31, 2022. Coauthor.
- “Russia Invades and the West Reacts: A Look at Russian Sanctions So Far,” February 25, 2022. Coauthor.
Education
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J.D., University of Michigan Law School, 2021
M.S., International Conflict Prevention and Peacebuilding, Durham University, 2018
With meritB.A., Political Science and English, University of Missouri, 2016
magna cum laude
Admissions
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District of Columbia