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Ann M. Nagele

Partner

Ann M. Nagele

For more than 20 years, Ann has assisted clients with a wide range of international commerce and licensing matters.

Ann Nagele advises clients on commercial (dual-use) and defense-related export licensing, compliance, and enforcement matters, U.S. trade sanctions, customs compliance, and Committee on Foreign Investment in the United States national security reviews. She also assists with export control-related matters that arise in various transactions, including mergers and acquisitions and stock purchase agreements.  

In her international trade practice, Ann represents clients in matters before various U.S. government agencies, including the Department of Commerce's Bureau of Industry and Security, the State Department's Directorate of Defense Trade Controls, the Treasury Department's Office of Foreign Assets Control, U.S. Customs and Border Protection, and the Census Bureau's Foreign Trade Division. 

Additionally, Ann drafts and negotiates licensing and technology agreements, including software licenses, manufacturing and reseller agreements, and consulting and services agreements. 

Education & Credentials

Education

  • Georgetown University Law Center, LL.M., International and Comparative Law, with distinction, 1999
  • Seattle University School of Law, J.D., cum laude, 1998
  • University of Washington, B.A., Political Science, magna cum laude, Phi Beta Kappa, 1989

Bar and Court Admissions

  • Washington

Related Employment

  • Asymetrix Corporation, Intellectual Property Paralegal, 1993-1995
  • Law Offices of Seed and Berry LLP,  International Trademark Paralegal, 1991-1993

Clerkships

  • Advocate General Philippe Léger, European Court of Justice of Luxembourg

Professional Recognition

  • Listed in Best Lawyers in America: Government Relations Practice, 2024-2025

  • Selected for “Rising Stars of Washington Law,” Washington Law & Politics, 2006

Impact

Professional Leadership

  • Washington Council on International Trade, Advisory Board Member (alternate), 2012-2017; Board Member 2017-present
  • Washington State Bar Association
  • American Bar Association, International Law Section
  • International Bar Association
  • Customs and International Trade Bar Association
  • Society for International Affairs

Community Involvement

  • InterConnection.org, Board Member, 2013-2017
  • Northwest Immigrant Rights Project

Professional Experience

Export Control Counseling

Exports/BIS and DDTC

Advised a broad range of companies on compliance with U.S. export controls on commercial/dual-use items under the Export Administration Regulations administered by the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and on defense articles under the International Traffic in Arms Regulations administered by the U.S. State Department's Directorate of Defense Trade Controls (DDTC). Submitted and obtained numerous export licenses and classification requests including for encryption items. Prepared and handled voluntary self-disclosures. Drafted and implemented corporate export compliance management systems and related policies for clients in a variety of industry sectors. Conducted export control compliance training.

U.S. Trade Embargoes and Sanctions/OFAC

Counseled clients on U.S. embargoes/sanctions programs administered by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC). Prepared and obtained export licenses from OFAC, including under the Trade Sanctions Reform Act (TSRA). Developed and implemented corporate OFAC compliance programs, including prohibited party screening mechanisms. Developed and conducted client internal OFAC compliance training. Prepared and handled voluntary self-disclosures to OFAC.

Foreign Trade Regulations/Automated Export System

Counseled variety of clients on compliance with the Foreign Trade Regulations (FTR), including filing of electronic export information (EEI) via AES/AES Direct to the U.S. Customs and Border Protection. Prepared and handled voluntary self-disclosures under the FTR.

Commodity Jurisdiction

Advised clients regarding agency jurisdictional issues (State Department/Directorate of Defense Trade Controls vs. Commerce Department/Bureau of Industry and Security) related to U.S. export controlled items, as well as the International Traffic in Arms Regulations (ITAR) in connection with such matters.

U.S. Customs Compliance/CBP

Counseled clients on customs issues involving import transactions including entry, classification, valuation, marking and rules of origin requirements. Advised clients on development and implementation of internal import compliance programs. Submitted and negotiated Petition for Relief for mitigation of U.S. Customs assessed penalties.

Exon-Florio/CFIUS

Counseled companies regarding the Exon-Florio Amendment and multi-agency Committee on Foreign Investment in the United States (CFIUS), including compliance with FINSA regulations. Advised on compliance with FINSA regulations and related issues (e.g., whether proposed transactions are "covered transactions" that may raise national security concerns, as well as on filing of voluntary notifications with CFIUS).

Technology Transactions & Privacy

Licensing and Technology Transactions

Drafted and negotiated the following for a wide variety of clients: software license agreements; OEM and reseller agreements; marketing and sales agreements; and consulting, services and Web hosting agreements. Prepared and negotiated trademark and patent licenses. Prepared Website terms of use and user agreements for various Internet and e-commerce companies. Conducted privacy audits and advised various companies regarding development of privacy policies, practices and related agreements.

FDA Regulatory Counseling/Medical Devices

Provided counseling to various medical device companies regarding compliance with FDA regulations. Assisted with FDA regulatory matters arising in various transactions, including mergers, acquisitions and stock purchase agreements involving medical device companies.

Immigration

Pro bono experience assisting individuals seeking political asylum and U-visas (for U.S. immigrants that are victims of criminal activity), with the Department of Homeland Security's U.S. Citizenship and Immigration Services.

Additional Experience

Government Contracts

Experience with the Federal Acquisition Regulations subcontractor "flowdown" requirements, as well as General Services Administration (GSA) contracts and related documents.

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