Kevin E. Gaunt

Kevin advises clients on white collar defense, government and internal investigations, and the full range of trade and regulatory enforcement matters—from OFAC sanctions and BIS export controls to DOJ investigations and False Claims Act defense. He is especially experienced in helping clients navigate enforcement environments that are simultaneously complex and fast-moving, including economic sanctions, tariff and trade restriction compliance, anti-corruption, and national security regulations.

His matters frequently involve OFAC economic sanctions, export controls under the EAR and ITAR, and import controls such as tariffs and US Customs and Border Protection regulations. Kevin has been extensively involved in advising clients on the trade policy disruptions of recent years, including IEEPA-based and reciprocal tariff regimes, tariff investigations, and the rapidly shifting sanctions landscapes affecting Russia, Venezuela, Iran, and other jurisdictions.

He also advises clients on financial crime, anti-money laundering, anti-bribery, anti-corruption and the Foreign Corrupt Practices Act (FCPA), government contracting fraud, and national security issues such as those arising under the Foreign Agents Registration Act (FARA). Kevin has prosecuted and intervened in bid protests before the US Government Accountability Office on behalf of clients with government contracts.

• Advised importers and manufacturers on legal and strategic responses to IEEPA-based and reciprocal tariff regimes, including tariff classification reviews, CBP entry summary analysis, prior disclosure evaluations, and assessment of refund litigation options following the US Supreme Court’s ruling that invalidated IEEPA tariff authority.

• Secured a Cautionary Letter from OFAC for a global employment agency in connection with OFAC’s enforcement initiative targeting North Korean IT worker networks operating through third-party front companies.
• Counseled clients on compliance opportunities and residual risks arising from OFAC’s easing of comprehensive sanctions on Venezuela and Syria in 2025–2026, including analysis of new general licenses and implications for energy sector and trade counterparties.
• Secured a Cautionary Letter from OFAC relating to a financial institution client’s voluntary disclosure of apparent violations of the Russia/Ukraine sanctions arising from transactions related to blocked Russian banks.
• Conducted internal investigation for global manufacturing company related to potential violations of the EAR in connection with the Entity List maintained by the Bureau of Industry and Security (BIS) of the US Department of Commerce.

• Drafted and submitted public comments to the Office of the United States Trade Representative on behalf of a chemical manufacturer advocating for the exclusion of a specialty chemical tariff subheading from proposed Section 301 duties in a forced-labor investigation.

• Secured a No-Action letter from BIS after a voluntary self-disclosure on behalf of a client related to potential export control violations stemming from a client contractor’s unauthorized travel to Iran.

• Advised multiple clients on FARA obligations and registration requirements, and prepared and submitted FARA registration statements to DOJ on their behalf.

• Advised numerous clients on the impacts of economic sanctions and export controls imposed on Russia following its invasion of Ukraine.
• Represented military housing provider in civil and criminal False Claims Act (FCA) investigation involving allegations of fraud related to requests for incentive fee payments tied to military base housing contracts with the government.
• Represented specialty vehicle manufacturer in DOJ investigation into potential FCPA violations arising from international sales contracts with a foreign government’s Ministry of Defense.
• Conducted internal investigation for county school board to facilitate board’s response to government investigation into qui tam relator’s allegations of bid-rigging and kickbacks relating to school contractors.
• Counseled numerous energy sector clients, including clients across the nuclear, oil and gas, and mining industries, on OFAC sanctions and risk exposure.

• Selected as One to Watch for Commercial Litigation, Criminal Defense: White-Collar, and Technology Law, The Best Lawyers in America, 2026
• Recipient of Lawyers Serving Warriors^® Excellence Award, National Veterans Legal Services Program, 2019

• Member, American Bar Association, Criminal Justice Section