Admissions
- Washington, DC
- Maryland
Education
- George Washington University Law School, J.D. (Managing Editor, The George Washington International Law Review), 2003
- University of Maryland at College Park, B.A., 1999
Overview
Michelle Roberts advises a broad range of clients – from startups, charities and NGOs to multinational corporations – on U.S. economic sanctions, export controls, and related national security regulatory matters before the Treasury Department’s Office of Foreign Assets Control (OFAC), Commerce Department’s Bureau of Industry and Security (BIS), and the State Department. She counsels clients on primary and secondary sanctions under all OFAC sanctions programs and on dual-use export controls under the Export Administration Regulations (EAR). In particular, Michelle has extensive experience advising on jurisdictional questions, licensing strategy, voluntary self-disclosures and enforcement, due diligence and risk management, design and enhancement of compliance programs and internal controls, delisting petitions, and assists clients seeking classification rulings. Ms. Roberts also has substantial experience conducting internal investigations and compliance audits, including serving on an external monitorship team appointed pursuant to a U.S. Department of Commerce settlement agreement.
Representative Experience
- Advised Indian pharma company regarding wind down of dealings with recently designated SDNs and secondary sanctions risks.
- Represented client in petition for removal from SDN List.
- Advised U.S. conglomerate on risk management and options concerning divestment of Russian subsidiary.
- Advised Russian energy companies regarding the scope of U.S. sanctions prohibitions, licenses, secondary sanctions risks, and related issues arising under U.S. sanctions on Russia.
- Advised companies on responding to OFAC administrative subpoenas and ensuing investigations and disclosures.
- Represented clients with respect to internal investigation and voluntary self-disclosures concerning violations of Russia, Iran, and other sanctions programs, and assessment of penalties.
- Obtained several EAR99 classification rulings for clients in various industries.
- Represented charities and NGOs concerning work in sanctioned territories and risk mitigation.
- Developed risk-based compliance programs for various clients.
Practice Focus
- OFAC Sanctions
- Export Controls
- Risk Management & Compliance Programs
- Internal Investigations & Enforcement
Publications & Speaking
- U.S. Eases Export Controls and Sanctions on Syria, International Enforcement Law Reporter, June 2025.
- Client Alert: U.S. Eases Export Controls and Sanctions on Syria
- OFAC Issues Maximum Penalty in Enforcement Against Venture Capital Firm, International Enforcement Law Reporter
- Part One: U.S. Eases Sanctions Against Cuba, Offshore Investment, April 2016, Issue 265
- Part Two: The U.S. Continues to Remove Restrictions on Cuba, Offshore Investment, April 2016, Issue 265
- Co-presenter, Practicalities and Risks of OFAC Licenses, Sanctions Alert, June 2017.
- Co-presenter, Contracts, Due Diligence and Screening, Deemed Exports and Technology Control Plans, U.S. Commercial Service, April 2017
- Panelist, Sanctions Year in Review, American Bar Association, February 2017.