Thomas C.R. Reynolds

Thomas Reynolds


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, and provides his legal counsel in compliance, transactional, policy and regulatory contexts.

Tom has the unique ability to provide detailed, technical guidance as well as high-level strategic counsel. His practice involves classifications under the Harmonized Tariff Schedule of the United States (HTSUS), Schedule B, Commerce Control List (CCL) and United States Munitions List (USML); customs valuation; jurisdictional analyses; licensing applications; development of compliance programs, policies and procedures; and other matters.

When needed, Tom has also represented clients in penalty and disclosure situations in front of Customs & Border Protection (CBP), the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC), and the Census Bureau, as well as internal audits.

Before joining DLA Piper, Tom practiced at boutique law firms in Chicago, focusing on litigation and international trade law.

Bar admissionsDistrict of ColumbiaIllinois
CourtsCourt of International TradeUnited States District Court for the Northern District of Illinois


  • 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
  • Manage trade-related due diligence in mergers and acquisitions (M&A) contexts
  • Classify exports and imports based on HTSUS, Schedule B, CCL, and USML, including dual-use encryption items
  • Consult on export license exceptions, general licenses, and file for export license 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
  • Spanish
  • Portuguese
  • French
  • J.D., Chicago-Kent College of Law, Illinois Institute of Technology 2013
  • B.A., Political Science & Religion, University of Florida 2009
    magna cum laude

Pro Bono

Tom has represented clients in various immigration, education, and voting rights pro bono matters. He has advised Spanish-speaking clients on potential immigration avenues for relief, another client in special education matters, and a not-for-profit advocating for citizens' voting rights.


  • 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


  • 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 232020

Additional Information

Tom has served in the following leadership roles:

  • HNBA Deputy National Secretary & HNBA, Young Lawyers Division regional representative 
  • Hispanic Lawyers Association of Illinois (HLAI) board member
  • Chicago Bar Association (CBA) Young Lawyers Section board member

Memberships And Affiliations

  • Hispanic National Bar Association (HNBA)
  • Hispanic Bar Association of the District of Columbia (HBA-DC)
  • DC Area Phi Beta Kappa Association (DCPBK)