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“Cortney O’Toole Morgan is fantastic to work with and she invests a lot in the client relationship.”

Chambers USA 2025

Overview

Cortney thrives in the fast-paced, ever-changing world of global international trade and supply chain management.

Leading the firm’s International Trade and Supply Chain practice, Cortney focuses her practice on the production, sourcing and movement of goods, services and technology across international borders. She advises foreign and domestic companies on all aspects of international trade, including regulatory compliance, supply chain efficiencies, investigations and enforcement. She stays current on world events as relationships shift among countries, in order to take a proactive approach to minimizing disruption in clients’ supply chains. Cortney also stays fully informed on the manufacturing, technology and transportation industries where many of the clients she serves operate—understanding clients’ businesses and challenges helps her better manage client risk and enhance client compliance.

Much of Cortney’s practice involves international trade controls, including export controls and economic sanctions. Her transactional work often involves advising clients on export and import licensing, tariff classification, valuation, country of origin marking, preference programs, IPR enforcement, customs audits, logistics security, penalties and voluntary disclosures. Cortney intimately understands the increasingly significant nexus between CFIUS and trade controls and frequently provides CFIUS-related guidance to both foreign and domestic companies.

Based in Washington, D.C., Cortney counsels clients on compliance with the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and economic sanctions programs administered by the Office of Foreign Assets Control (OFAC), as well as anti-boycott programs administered by the U.S. Departments of Commerce and Treasury.

Cortney is a member of the firm's Governance and Nominating Committee.

“Cortney O’Toole Morgan is fantastic to work with and she invests a lot in the client relationship.”

Chambers USA 2025

Industries

Services

Recognition

  • Chambers and Partners 
    • USA-Nationwide, International Trade: Export Controls & Economic Sanctions, 2021-2025
    • Global Guide, USA, International Trade: Export Controls & Economic Sanctions, 2022-2025
  • JD Supra Readers' Choice Awards, Top Author, International Law, 2023 and 2024
  • Thomson Reuters Stand-out Lawyer, 2023-2025

Education

  • J.D., The Catholic University of America
      • Chancellor, Phillip C. Jessup International Law Moot Court Competition, 1999-2000
      • Lead Articles Editor, CommLaw Conspectus: Journal of Communications Law and Policy, 2000-2001
      • Moot Court Associate, Fall 1998-Spring 1999
      • Vice-President, International Law Society, 1999-2000
      • Women’s Law Caucus
  • B.A., American University
    • International Relations (Asia and Foreign Economic Policy)
  • Ritsumeikan University
    • Japanese, Economics

Admissions

  • District of Columbia
  • New York
  • U.S. Court of Appeals, District of Columbia Circuit
  • U.S. Court of Appeals, Federal Circuit
  • U.S. Court of International Trade
  • U.S. District Court, District of Columbia

Professional Memberships and Certifications

  • American Bar Association, Section of International Law
    • International Trade Committee, Co-chair, 2013-present, Senior Advisor, 2015-2016
    • Customs Law Committee, Co-chair, 2008-2011, Senior Advisor, 2012-2013
    • Export Controls and Economic Sanctions Committee, Vice Chair, 2012-2013, 2018-present
  • Customs and International Trade Bar Association, 2001-present
  • Law360 International Trade Editorial Advisory Board, 2018-2021
  • National Association of Manufacturers
  • The Society of Chemical Manufacturers & Affiliates, International Trade Committee
  • Washington International Trade Association, 2002-present
  • Organization of Women in International Trade, Board of Directors
  • District of Columbia Bar, International Law Community, Co-Chair, 2017-present

Languages

  • Japanese, fluent
  • Spanish, conversant

We have a ton of incredible resources available to help our attorneys think like and understand our clients so that we can be better partners.

Experience

Export Controls & Economic Sanctions

  • Provide routine counseling and advice to multinational fast-growing consumer goods company on U.S. sanctions and export controls compliance.
  • Counseled global services provider on compliance with U.S. sanctions programs, including development of multijurisdictional guidance and compliance procedures for conducting global trade operations.
  • Assisted client in matters involving U.S. export controls and trade sanctions including advice relating to ongoing sales, installation and training activities performed in Iran and associated payment transactions conducted under various General Licenses issued by the U.S. Treasury Department – Office of Foreign Assets Control (OFAC).
  • Served as outside export controls and trade sanctions compliance counsel to a publicly traded transportation company including entry into a joint venture with a Russian counterparty which involved the transfer of certain product designs to the joint venture and the development of appropriate safeguards to prevent the joint venture from potential reexports to prohibited and sanctioned parties in Russia or the Crimea Region of Ukraine.
  • Represented numerous clients in mergers and acquisitions activities, including conducting and responding to import and export activity related due diligence, and preparing representations and warranties related to trade controls compliance.
  • Advised global technology company on International Traffic in Arms Regulations (ITAR) and trade control matters related to its merger with another technology company, including migration of export registration, licenses and integration of compliance policies for the merged entity.
  • Assisted in an internal export compliance review of client's export shipments of EAR and ITAR controlled aviation equipment and parts, including preparing and submitting various voluntary self-disclosures under the EAR and Census Foreign Trade Regulations, as well as advising and assisting client in conducting an internal investigation relating to certain unauthorized shipments to countries in the Middle East.
  • Provides day-to-day trade compliance advice related to export licensing, export controls, economic sanctions and other international trade matters with a heavy focus on encryption related controls.
  • Conducted an ITAR investigation of a multinational freight forwarder handling aerospace products and represented client before U.S. Department of State Directorate of Defense Trade Controls (DDTC).
  • Advised U.S. oilfield services company and European affiliates regarding U.S. sanctions and export control implications associated with a proposed multimillion-dollar contract to provide offshore geotechnical services related to natural gas pipeline evaluation and construction in Russia, Eastern Europe and the Black Sea.
  • Assisted non-U.S. energy services company in evaluation of a proposed joint project with another non-U.S. company, for seismic exploration in the Arctic on behalf of a Russian oil company, in connection with the U.S./Ukraine-related sanctions.
  • Provides ongoing advice to a global technology company on ITAR, export controls (including ICTS) and sanctions related matters associated with multi-year global IT services contracts. This advice allows the company's business teams to properly analyze and mitigate potential risk for the company so that a determination can be made quickly and effectively by stakeholders.
  • Represented global media and communications clients before the Office of Foreign Assets Control in sanctions investigations.
  • Provided counseling and assistance with voluntary and directed disclosures to BIS, DDTC and U.S. Census Bureau regarding compliance issues, including unlicensed exports of goods and technical data.

International Trade Remedies

  • Represented members of the U.S. tape manufacturing industry before the U.S. International Trade Commission (USITC) in seeking renewal of a decades old antidumping duty finding concerning pressure sensitive plastic tape from Italy. Convinced the USITC that threat of injury to the domestic tape industry still existed if the order was revoked. As a result, the USITC made an affirmative determination and the existing antidumping duty finding remained in place.

Customs

  • Conducted global reviews of companies' import and export compliance programs with follow-up training.
  • Obtained favorable rulings from U.S. Customs and Border Protection (CBP) with substantial duty savings for pharmaceutical and chemical industry clients concerning country of origin marking and preferential duty qualifications.
  • Advised large pharmaceutical and biotechnology companies on transfer pricing and customs valuations-related issues and establishment of value reconciliation programs.
  • Assisted global consumer products company in all phases of CBP Focused Assessment audit.

Committee on Foreign Investment in the United States (CFIUS)

  • Obtained CFIUS clearance for an acquisition by a non-U.S. company of a leading supplier to the defense and nuclear power industries.
  • Counseled a U.S. aerospace manufacturer regarding CFIUS matters in connection with potential Chinese foreign investors.
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Blog | March 07, 2025
Articles | March 06, 2025
Articles | February 25, 2025
Articles | February 20, 2025
Articles | February 11, 2025
Articles | February 07, 2025
Articles | February 07, 2025
White Papers | December 17, 2024
International Trade Law: 2024 Year in Review & Outlook for 2025

Few areas will be as impacted by the incoming second Trump administration as international trade policy. Check out our team’s assessment of what the coming year may bring for trade regulation and enforcement.

Blog | November 26, 2024
Articles | November 15, 2024
Legal Insights for Manufacturing: International Trade

November’s U.S. presidential election will play a significant role in determining the trajectory of trade policy; however, there are also larger trends at work that will likely transcend the election and persist well into the future.

White Papers | October 24, 2024
Legal Insights for Manufacturing: Outlook for 2025

Intensifying geopolitical crises, increasing regulatory burdens, and uncertain macroeconomic conditions have led to an era of caution for manufacturers.

Blog | October 02, 2024
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Articles | September 10, 2024
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Blog | January 03, 2024
White Papers | December 28, 2023
International Trade Law: 2023 Year in Review & Outlook for 2024

U.S. importers and exporters are navigating a new enforcement landscape where government officials are working collectively across agencies and increasingly leveraging new technologies.

White Papers | November 01, 2023
Legal Insights for Manufacturing: Outlook for 2024

With each passing day it becomes more apparent the world that entered the COVID-19 pandemic is not the world that emerged from it.

Blog | September 29, 2023
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Blog | February 27, 2023
Blog | February 27, 2023
Blog | February 27, 2023
Blog | February 27, 2023
Blog | February 14, 2023
Blog | February 10, 2023
White Papers | January 04, 2023
Legal Insights for Manufacturing: Outlook for 2023

What manufacturers can expect in the new year.

White Papers | December 21, 2022
International Trade Law: 2022 Year in Review & Outlook for 2023

How to get trade ready in 2023.

Blog | December 20, 2022
Blog | December 16, 2022
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Articles | March 13, 2022
Blog | March 10, 2022
Blog | March 07, 2022
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Articles | February 03, 2022
Blog | February 02, 2022
Articles | January 30, 2022
Articles | January 26, 2022
Blog | January 21, 2022
Blog | January 20, 2022
White Papers | December 2021
International Trade Law: 2021 Year in Review & 2022 Outlook

How to get trade ready in 2022.

Articles | October 27, 2021
Blog | October 22, 2021
Articles | October 20, 2021
Blog | October 13, 2021
Blog | October 04, 2021
Articles | September 02, 2021
Articles | September 01, 2021
Blog | August 30, 2021
Articles | August 27, 2021
Blog | August 26, 2021
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Blog | August 12, 2021
Articles | July 31, 2021
Articles | July 30, 2021
Blog | July 27, 2021
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Articles | March 19, 2021
Blog | March 12, 2021
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Blog | March 02, 2021
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Blog | February 15, 2021
Articles | February 08, 2021
Blog | February 05, 2021
Articles | January 25, 2021
Blog | January 20, 2021
Blog | December 23, 2020
Blog | December 23, 2020
White Papers | December 2020
International Trade Law: 2020 Year in Review & 2021 Outlook

How to get trade ready in 2021.

Blog | December 21, 2020
Blog | December 21, 2020
Blog | December 18, 2020
Articles | December 09, 2020
Articles | December 04, 2020
Blog | December 03, 2020
Articles | December 02, 2020
Blog | November 25, 2020
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Blog | November 03, 2020
Articles | September 25, 2020
Articles | September 24, 2020
Blog | September 23, 2020
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Articles | September 11, 2020
Blog | September 08, 2020
Articles | August 26, 2020
Articles | August 25, 2020
Blog | August 21, 2020
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Blog | August 07, 2020
Blog | July 21, 2020
Articles | July 09, 2020
Blog | July 08, 2020
Blog | June 22, 2020
Media Mentions | January 09, 2025
Media Mentions | August 24, 2023
Media Mentions | August 24, 2023
Media Mentions | August 09, 2023
Media Mentions | March 30, 2023
Media Mentions | April 09, 2021
Outside the Office

Cortney has two children who enjoy sports, and one way she participates in their activities is by managing their swim teams.

As a former high school swimmer, she likes spending time at the pool. Cortney also enjoys running, reading and traveling internationally with her family.

Community Leadership

Cortney mentors and networks with fellow alumni in the D.C. area.

As a graduate of Emma Willard School, an all-girls private boarding high school, Cortney actively participates in alumni activities with the D.C. Chapter. She attends networking events with women of all generations and mentors other women in their lives and careers. Cortney enjoys how the women of all ages share a common experience but have vastly different careers and life experiences.

International Trade

Living in Japan was instrumental in shaping Cortney's international legal career.

Cortney always loved languages and had a keen interest in Asian culture. As a college freshman, she took advantage of an opportunity to participate in a one-year, intensive exchange program at Ritsumeikan University in Kyoto, Japan. Living abroad and speaking fluent Japanese changed her perspective on the world and influenced her career choice. Her immersion in a different culture has helped her understand the importance of nuances in international trade.