Kay C. Georgi

Partner

Kay is a partner in the International Trade group and has more than 34 years’ experience advising clients on all aspects of international trade, with particular capability in the areas of export control and sanctions, Foreign Corrupt Practices Act (FCPA), and import (customs) matters.

Kay Georgi Portrait

Ranked as one of the nation’s leading International Trade: Export Controls & Economic Sanctions lawyers by Chambers USA, and as a leading international trade practitioner by Legal 500 and Expert Guides, Kay is known for helping large and small clients understand, comply with, and weather the investigation storms associated with the complicated set of US laws and regulations governing US exports and non-US re-exports of goods, software, services, and technology, and US economic sanctions. 

Kay also counsels clients on the Committee on Foreign Investment in the United States (CFIUS) and its expanded authority under the Foreign Investment Risk Review Modernization Act (FIRRMA). She advises both investors and target companies on transactions involving critical technology, and sensitive personal data, including mergers and acquisitions, venture capital investments, and private equity transactions. She advises clients on the regulatory implications of various transactions and regularly prepares filings for CFIUS review. She also advises clients on the new export controls on emerging and foundational technologies, as mandated by the Export Control Reform Act of 2018 and how they intersect with CFIUS’s jurisdiction. More recently, she has advised clients in US Department of Commerce investigatory and rulemaking proceedings under Information and Communications Technology and Services (ICTS) Executive Orders. She also has experience advising clients on issues involving trade agreements, including World Trade Organization (WTO) agreements.

Some of Kay’s recent engagements:

  • Assist in submitting comments in ICTS rulemaking proceeding
  • Lead auditor in International Traffic in Arms Regulations (ITAR) audits conducted pursuant to the Directorate of Defense Trade Controls (DDTC) of the Department of State consent agreement/directed disclosures
  • Expert witness on ITAR and economic sanctions issues in international arbitrations
  • Advisor to non-US companies responding to US criminal and civil government inquiries related to non-US trade in dual-use goods/services with US embargoed countries, including Russia and China 
  • Conduct global reviews of Fortune 500 companies’ export and import compliance programs and provide training to those companies
  • Provide counseling and investigative experience and assistance in voluntary and directed disclosures to a wide range of industries

Client Work

Kay has significant experience in export control matters, including advising clients on US and international laws relating to the export and import of defense articles, services, and technologies, as well as dual-use goods and technologies, and nuclear equipment and technologies. She regularly represents clients before the Bureau of Industry and Security (BIS) of the Department of Commerce, the DDTC of the Department of State, and the Office of Foreign Assets Control (OFAC) of the Department of Treasury. She is experienced in the management and resolution of:

  • Licensing
  • Commodity jurisdiction and classification requests
  • Internal and external audits
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Kay has particular industry knowledge in the areas of:

  • Defense
  • Consumer products
  • Aircraft/aerospace/space including satellites and other spacecraft
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Kay also advises clients regarding compliance with anti-corruption laws, including the FCPA, and assists in internal and US government investigations relating to the FCPA and commercial bribery. More recently, Kay has advised clients on compliance with US customs-related laws and regulations administered by the Customs and Border Protection (CBP).

Previous Work

Kay formerly was an associate and partner from 1989 to 2005 with Coudert Brothers LLP.

Professional Activities

Kay is a member of the American Bar Association (ABA), Section of International Law and Practice, and has twice served as Co-chair of the ABA Export Controls & Economic Sanctions Committee. She is also a member of the New York State Bar Association.

Publications, Presentations & Recognitions

Kay has been recognized by Chambers USA as one of the nation’s leading International Trade: Export Controls & Economic Sanctions lawyers. Kay has also been recognized as a leading international trade practitioner by Legal 500, Expert Guides, and Who’s Who Legal.

Kay’s recent publications include:

  • Co-author “Foreign Trade Law,” Heidelberg Commentary, CF Müller (2024). 
  • Co-editor “International Guide to Export Controls and Economic Sanctions,” 2nd Edition: American Bar Association (2023).
  • Co-author, “Five takeways on the DDTC’s new ITAR OGLs for Australia, Canada and the UK,” Export Compliance Manager: Issue 26 (2022).
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Kay’s recent speaking engagements include:

  • “Sanctions & Blocking Statutes – Managing Terrorism, Geopolitics and the Movement of Goods & Services Globally,” Inter-Pacific Bar Association Annual Meeting and Conference, April 24, 2025
  • Co-Chair: “14th Annual Advanced Forum on Global Export Controls,” American Conference Institute, February 25-26, 2025
  • “Compliance Best Practices – Industry Perspectives,” Practising Law Institute Conference, Coping with US Export Controls and Sanctions, December 10, 2024
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Life Beyond the Law

Kay enjoys playing euphonium in local bands (Oktoberfests a specialty), gardening, motorcycle touring, and working out at her favorite gym.

Awards

Awards

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Firm Logo

US Hall of Fame 2024