Soo-Mi Rhee | People | Arnold & Porter

A trusted adviser to major corporations facing high-stakes criminal and regulatory investigations, Soo-Mi Rhee, who leads the firm’s Anti-Corruption practice, offers extensive experience in major anti-corruption, compliance, national security, and export controls and sanctions issues, with particular expertise in high-tech industries. Soo-Mi helps companies and institutions establish compliance programs, obtain export authorizations, obtain product classifications, conduct compliance risk assessments/audits, and conduct internal investigations. She also regularly represents clients in economic sanctions, export controls, and/or Foreign Corrupt Practices Act (FCPA) enforcement proceedings before the Office of Foreign Assets Control, U.S. Department of the Treasury (OFAC), the Bureau of Industry and Security, U.S. Department of Commerce (BIS), the Directorate of Defense Trade Controls, U.S. Department of State (DDTC), U.S. Department of Justice (DOJ) and/or U.S. Securities and Exchange Commission (SEC).

In addition, Soo-Mi assists clients with concerns regarding U.S. national security-based foreign investment restrictions administered by the Committee on Foreign Investment in the United States (CFIUS).

In law school, Soo-Mi was executive managing editor of the Columbia Law Review and a Harlan Fiske Stone scholar. She is fluent in Korean.

Focus Areas

Experience

International financial institution in an ongoing U.S. government-initiated investigation of potential U.S. sanctions violations being conducted by SDNY, NYAG, NYDFS, FRBNY, FRBSF, and OFAC.
Korean-based shipbuilder in a Deferred Prosecution Agreement with the DOJ, coordinated Leniency Agreements with the three government agencies in Brazil, and collateral litigation related to the high-profile "Operation Car Wash" scandal involving Petrobras.
Oil and gas data processing company in self-reported DOJ, OFAC, and BIS investigation of potential violations of the FCPA, U.S. economic sanctions, and U.S. export controls.
Major medical device manufacturer in U.S. government-initiated, multi-continent DOJ, OFAC, and BIS investigation of potential violations of U.S. economic sanctions and U.S. export controls.
Global airline company in an internal investigation of potential U.S. economic sanctions violation.

Defense component reseller in an investigation initiated by CBP and DHS of potential U.S. export controls.
Global pharmaceutical company in leading an anti-trust and anti-corruption internal investigation related to a criminal proceeding outside the United States.
Technology company in an internal investigation related to a potential diversion of company’s products to sanctioned countries, as well as assisting the company in responding to an OFAC subpoena.
Global Fortune 20 consumer electronics and telecommunications company in conducting a global FCPA/anti-corruption compliance risk assessment.
Fortune 200 IT and professional services company in conducting a global FCPA/anti-corruption risk assessments, due diligence, and compliance program integration relating to more than a dozen international corporate acquisitions.
General counsel of a major oil and gas company in U.S. government-initiated, multi-continent DOJ, SEC, OFAC, and BIS investigation of potential violations of the FCPA, U.S. economic sanctions, and U.S. export controls.
Major financial institution in self-reported OAC investigations of potential violations U.S. antiboycott laws.
Oil and gas company in self-reported DOJ and SEC investigation of potential violations of the FCPA.
Fortune 100 defense contractor in self-reported DDTC investigations of potential violations of U.S. export controls.
Logistics company in self-reported OFAC investigation of potential violations of U.S. export controls.
Private equity funds in conducting internal FCPA/anti-corruption, economic sanctions, and export controls audits of newly acquired portfolio companies.