Thomas ReynoldsSenior Attorney
Thomas Reynolds focuses his practice in the area of U.S. international trade and investment law, including export controls, sanctions, embargoes, import/customs, and foreign investment matters. For nearly a decade, he has provided legal counsel in compliance, transactional, policy, regulatory, litigation/arbitration and educational contexts.
Tom has conducted international trade due diligence on hundreds of mergers and acquisitions, regularly represents clients in front of U.S. federal agencies, and provides counsel to clients on compliance with the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), Nuclear Regulatory Commission (NRC) export controls, Office of Antiboycott Compliance (OAC) antiboycott rules, Foreign Trade Regulations (FTR), and foreign investment requirements administered by the Committee on Foreign Investment in the United States (CFIUS) and the Bureau of Economic Analysis (BEA).
His practice can range from strategic guidance, such as setting up and implementing trade compliance programs or implementing guardrails to doing business in Russia/Belarus, to detail-oriented matters, such as jurisdictional analyses and proper classification under the Harmonized Tariff Schedule of the United States (HTSUS), Schedule B, Commerce Control List (CCL) and United States Munitions List (USML).
When needed, Tom has also successfully advocated for clients in license applications and represented companies in penalty and disclosure situations with Customs & Border Protection (CBP), the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC), the Census Bureau, and in internal audits and investigations.
Before joining DLA Piper, Tom practiced at boutique law firms in Chicago, focusing on litigation and international trade law.
- Manage international trade-related due diligence in hundreds of mergers and acquisitions (M&A) and other investments
- Administered international team of lawyers for medical device company in wake of COVID-19 to track trade and labor/employment laws
- Quickly organized trade lawyers and customs brokers in Latin America and other countries to successfully advise client of global import laws in emergency situation
- Successfully advocated for and obtained export licenses for semiconductors and technology to denied parties
- Advise on the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), OFAC sanctions programs, Foreign Trade Regulations (FTR), Committee on Foreign Investment in the United States (CFIUS) requirements, Bureau of Economic Analysis (BEA) rules, and CBP regulations
- Classify items for export/import based on HTSUS, Schedule B, CCL, and USML, including dual-use encryption items
- Consult on export license exceptions, general licenses, and file for export licenses, specific licenses and classification requests, including License Exception ENC for software/technology companies
- Draft and file disclosures of potential trade-related violations with BIS, OFAC, Census, DDTC and CBP
- Counsel on foreign investment and CFIUS considerations, including identification of critical technology in context of mandatory declarations
- Advise on BEA surveys of foreign direct investment into the United States, U.S. direct investment abroad, and transactions in selected services and intellectual property with foreign persons
- Manage Office of Antiboycott Compliance (OAC) antiboycott reviews for companies doing business in the Middle East or with boycotting countries
- Experience with internal and external audits, and establishing import/export compliance programs
- Evaluate proper customs business and compliance standards of companies importing goods into the United States, including valuation, transfer prices, country of origin, marking/labeling, and OGA/PGA import rules
- Construct mitigation framework for Section 301 and Section 232 duties
- J.D., Chicago-Kent College of Law, 2013
- B.A., Political Science & Religion, University of Florida, 2009, magna cum laude
- Top Lawyers Under 40 (2023), Hispanic National Bar Association
Tom is active in a variety of pro bono matters, including those involving education law, criminal defense and civil rights. He uses his Spanish language skills to communicate with clients regarding immigration, refugee, and asylum matters.
- Author, "Human Rights and Non-Discrimination in International Trade: Antiboycott Regulations," HNBA October 2022 E-Noticias
- Author, "Our voice, and our power, are limited when doing business with Cuba and Venezuela," Noticias 2021 HNBA/VIA Corporate Counsel Conference
- Speaker, "International Trade as it relates to the industrials sector," Internal DLA Piper Presentation, February 15, 2023
- Speaker, "The EU’s Carbon Border Adjustment Mechanism: potential impacts for Brazilian and US exports," DLA Piper Virtual Event, February 2, 2023
- Speaker, "Q&A with Tom Reynolds on export controls, sanctions and other national security laws affecting the tech sector," Internal DLA Piper Presentation, December 6, 2022
- Panelist, "Effective Supplier Code Frameworks," 2022 HNBA/VIA Annual Convention, September 8, 2022
- Speaker, "Not to be confused: CFIUS & BE-13 Surveys," Internal DLA Piper Presentation, July 28, 2022
- Panelist, "Global Ripple Effect of Russian Sanctions," HNBA Compliance and Ethics Committee Monthly Call, May 31, 2022
- Presenter/Trainer, "Attracting Foreign Direct Investment," Special Economic Zone Course, University of the Western Cape, May 10, 2022
- Presenter/Trainer, "Attracting Foreign Direct Investment," Special Economic Zone Course, University of Pretoria, May 29, 2021
- Moderator, "Import/Export in the Time of COVID-19 and Future Pandemics," HNBA 2020 Corporate Counsel Conference & Annual Convention, September 23, 2020
Tom has served in the following leadership roles:
- Hispanic National Bar Association Deputy National Secretary & Young Lawyers Division regional representative
- Hispanic Lawyers Association of Illinois board member
- Chicago Bar Association, Young Lawyers Section board member
Memberships And Affiliations
- Hispanic National Bar Association
- Hispanic Bar Association of the District of Columbia
- Society for International Affairs
- American Bar Association
- DC Area Phi Beta Kappa Association
My latest insights
BIS increases incentives for companies to report their own and others’ export control...
28 April 2023 .4 minute read