Professional profile
About Jeff
Jeff Farley advises Chinese and multinational companies facing US sanctions listings, export-control designations and related government investigations, with a practice built around administrative removal proceedings, regulatory engagement and litigation-oriented case strategy in Washington DC.
Jeff Farley practises at Farley & Rudman, PLLC in Washington DC. He concentrates on US export controls and economic sanctions, including the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security (BIS), and the sanctions programmes and lists administered by the Office of Foreign Assets Control (OFAC) at the US Department of the Treasury. His work regularly involves clients whose global funding, supply chain and reputation are affected by a listing decision, and who need a practical route back to compliance and normal commercial operation.
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For companies that have been added to a screening list or otherwise designated, the first questions are usually factual: what evidence supports the designation, what the company can document about its ownership, end users and transactions, and what the applicable removal or delisting procedure requires. Jeff Farley structures that response as a written case plan rather than a generic statute summary, and works with the company's own counsel to sequence each step.
Being named on a US control list can interrupt payments, logistics, insurance and customer relationships. Removal requires the right procedure, a complete evidentiary record and consistent engagement with the responsible agency.
Jeff Farley's approach is to treat each removal case as a compliance reconstruction project: identify the facts that matter to the agency, fix what can be fixed, document what cannot be changed, and present the record in a way that the agency can act on.
When a company or its management faces a US government investigation, subpoena, administrative proceeding or potential penalty action, the priority is to preserve the ability to respond accurately and to keep the matter within the appropriate forum.
Investigation response is fact-intensive and time-sensitive. Jeff Farley works with company personnel and outside advisers to build an accurate record early, avoid inconsistent statements across channels, and give decision-makers a clear picture of exposure and options.
Chinese companies can face parallel legal demands: US sanctions and export-control rules on one side, and Chinese countermeasures, blocking rules and the Anti-Foreign Sanctions Law on the other. Neither regime can simply be ignored, and compliance with one does not automatically satisfy the other.
Conflict-of-law work requires coordination between US counsel and counsel in the client's home jurisdiction. Jeff Farley's DC practice is well positioned for that coordination because the relevant agencies, administrative forums and federal courts are close at hand.
Engagements are confirmed in writing, including scope, fees and communication protocols. Jeff Farley does not promise outcomes; the commitment is accurate analysis, disciplined preparation and clear updates as facts evolve.
When using this profile's contact form, please include: the parties involved and their ownership structure; the listing, designation, investigation or penalty action at issue; the transaction or conduct that created the exposure; relevant dates and deadlines; and the first document set you can share. Clear inputs allow useful triage without repeated clarifying rounds.
If Chinese counsel, auditors or compliance consultants are already involved, say so at intake. Coordinated messaging reduces inconsistent statements across channels, which is an avoidable source of risk in multi-jurisdiction matters.
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