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F. Amanda DeBusk


F. Amanda DeBusk is the chair of Hughes Hubbard’s International Trade Department, where she heads the firm’s export controls and sanctions practice. She has a broad practice advising on U.S. international trade regulations that govern imports, exports, and trade compliance. She is a widely recognized authority in the enforcement of export controls and sanctions, drawing on her background as the former U.S. Commerce Department Assistant Secretary for Export Enforcement to handle civil and criminal enforcement matters and voluntary disclosures. Amanda also advises clients in matters involving the Foreign Corrupt Practices Act, trade remedies, customs, national security regulatory issues and the Committee on Foreign Investment in the United States (CFIUS), Buy America Act, and market access.

Her clients include Fortune 500 companies, leading non-U.S. based multinationals, foreign governments, and individuals. Amanda’s practice covers a wide variety of sectors, including defense, energy, manufacturing, network systems, satellites, semiconductors, electronics, automotive, aerospace, agriculture, telecommunications, and banking.

Areas of Experience

  • Export controls, including the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), export enforcement, and antiboycott matters, including voluntary and directed disclosures, internal investigations, audits, global compliance programs, classification and commodity jurisdiction requests, licensing, manuals and compliance materials, and training programs
  • Sanctions, including compliance advice, internal investigations, and Office of Foreign Assets Control (OFAC) licensing
  • Antidumping, countervailing duty, escape clause, and Section 332 investigations
  • Customs matters, including penalty proceedings, audits, and prior disclosures
  • Section 337 (IPR)
  • Foreign Corrupt Practices Act, including experience as part of a monitorship team
  • The Committee on Foreign Investment in the United States, including complex issues and strategy arising in large global acquisitions
  • National security regulatory issues
  • Trade agreements and market access, including the World Trade Organization, the North America Free Trade Agreement, various free trade agreements, the Wassenaar Arrangement, the Australia Group, the Missile Controls Technology Regime, and the World Customs Organization
  • Global settlements of criminal and civil export controls investigations with the U.S. Departments of Justice, Commerce, Treasury, State, and Homeland Security
  • Buy America Act and government contract issues
  • Overseas Private Investment Corporation, including expropriation claims

Professional Activities

  • Former U.S. Commerce Department Assistant Secretary for Export Enforcement
  • Member, State Department Advisory Committee on International Economic Policy: Sanctions Subcommittee
  • Member, Council on Foreign Relations
  • Trustee Emeritus, University of Richmond Board of Trustees
  • Co-chair and speaker for numerous conferences
  • Provided expert testimony on international trade issues for two Senate committees
  • Former counsel to the chair of the President’s Advisory Committee on Trade Policy & Negotiations
  • Former commissioner, Federal Interagency Commission on Crime and Security in U.S. Seaports
  • Former member, U.S. Trade Representative’s Investment and Services Policy Advisory Committee
  • Senior advisor, Women in International Trade Charitable Trust
  • Board of Editors, Westlaw Journal White-Collar Crime
  • Member, Trade Policy Forum


  • Top ranked in Chambers Global: The World’s Leading Lawyers for Business (International Trade)
  • Top ranked in Chambers USA: America’s Leading Lawyers for Business (International Trade)
  • In 2011 and 2013, Hughes Hubbard’s International Trade Department was nominated by Chambers USA as one of the top six law firm departments reflecting notable achievements over the past 12 months, including outstanding work, impressive strategic growth, and excellence in client service
  • Lifetime Achievement Award, Women in International Trade
  • Award for Outstanding Advocate for Women in Federal Law Enforcement
  • Recognized in the Best Lawyers in America in International Trade and Finance Law
  • Recognized in The Legal 500, “Leading Lawyer in International Trade”
  • Recognized in The International Who’s Who of Trade & Customs Lawyers
  • Recognized in the Guide to the World’s Leading Women in Business Law
  • Distinguished Alumni Service Award, University of Richmond

Court Admissions

  • U.S. Court of International Trade
  • District of Columbia Court of Appeals
  • U.S. District Court for the District of Columbia

Practice Groups and Other Information

Education Information

  • Harvard Law School, J.D., 1981
  • University of Richmond, B.A., 1978
    summa cum laude

Bar Admissions

  • District of Columbia, 1981

Selected Lectures and Publications

  • “U.S. Customs Law and Compliance,” Corporate Legal Departments: Practicing Law in a Corporation, (updated yearly) (co-author).  
  • "On the Ground in Iran & Cuba: Navigating Thorny Compliance Issues and Legal Frameworks" (12th Annual TRACE Forum, Washington, D.C., March 2, 2016).
  • "Untangling Common Issues in OFAC’s Revised 50 Percent Rule," The Export Practitioner, co-author (February 2016).
  • "Deciphering Differences in License Requirements under ITAR and EAR and Ensuring Each Product has the Correct License Under Its Jurisdiction" (C5’s 5th Conference on US Defense Trade Controls Under State and Commerce, London, UK, January 20-21, 2016).
  • "Russia/Ukraine Case Studies: How to Resolve Challenges in Implementing the 50% Ownership Rule" (6th Annual Economic Sanctions Boot Camp, New York, NY, December 1-2, 2015).
  • "Russia-Ukraine Sanctions: What You Need to Know" (Moderator, Knowledge Congress, webinar, October 8, 2014).
  • "Moot Court on the Top 3 Most Confronted Issues in Export Controls: An Interactive Debate on the 'Specially Designed' Definition, and Other Changes" (Judge, American Conference Institute's 17th National Forum on Global Export Controls Compliance, Washington, D.C., June 12-13, 2014).
  • "Compliance Strategies for Navigating New and Expanded Iran Sanctions Restrictions" (Co-Chair, The International Congress on Anti-Money Laundering and Sanctions Compliance, Washington, D.C., June 20-21, 2013).
  • Co-Chair of Conferences, American Conference Institute; 1st-5th National Forum of Export Enforcement Investigations (various years).
  • "The Story Behind Standard Chartered Bank’s $340M Settlement," with Lynn Kamarck, WorldECR The Journal of Export Controls and Compliance, Issue 15 (September 2012).
  • "Record-Breaking Fines in ING Bank Sanctions Case Show Hazards Of Doing Business with Iran, Cuba and Other Sanctioned Countries," Westlaw Journal White-Collar Crime, Vol. 23 no. 11, co-author (August 2012).
  • "EAR-ITAR Migration: How to Identify and Manage Migration Risks throughout the R & D and Product Life Cycle" and "What Triggers a BIS Visit or Inquiry: What to Expect and How to Prepare" (American Conference Institute’s EAR Boot Camp, Dallas, TX, January 25-26, 2012).
  • "How to Comply with New Foreign, Dual and Third Country National Rules: Reconciling ITAR and Form I-129 Requirements with Foreign Anti-Discrimination and Privacy Law Restrictions" (Co-Chair and Panelist, American Conference Institute’s ITAR Boot Camp, Chicago, IL, October 26-27, 2011).
  • "How Much an EAR Violation Can Cost Your Company: Lessons Learned from Recent Enforcement Actions" and "Vetting and Monitoring Third Party Compliance: Preventing Harsh Penalties for the 'Sins of Others in Your Supply Chain'" (Panelist, American Conference Institute’s Export Administration Regulations Boot Camp: How to Implement and Monitor an Effective Export Management and Compliance Program, Dallas, TX, January 26-27, 2011).
  • "Deemed Export Enforcement: Meeting Agencies’ Expectations for IT Controls of Technical Data" (American Conference Institute’s 5th National Forum on Export Enforcement and Investigations, Washington, D.C., January 28-29, 2010).
  • "What To Do If You Discover an Export Controls Violation" (American Conference Institute's 12th National Forum on Export Controls - Global Compliance Strategies, Washington, D.C., May 19-20, 2009).
  • "The Story Behind the Term 'Routed Transaction,'" Northrop Grumman’s Ex/Im Daily Update (July 27, 2009).
  • "What To Do If You Discover an Export Controls Violation" (American Conference Institute's 12th National Forum on Export Controls - Global Compliance Strategies, Washington, D.C., May 19-20, 2009).
  • "Export Controls Workshop" (11th National Forum on Export Controls – Global Compliance Strategies, Washington, D.C., May 28-30, 2008).
  • "Lessons Learned From The Northrop Grumman Case: The U.S. State Department’s Posture Toward Disclosures And Cooperation," with Daniel McLaughlin and Daniel Solomon, International Government Contractor 4, no. 5 (May 2008).
  • "Managing Volatility in Latin America" (Hughes Hubbard & Reed Client Seminar, Miami, FL, March 13, 2008).
  • "U.S. Reexport Controls And How They Affect Your Business" (10th Annual Global Trade Controls Conference, London, England, November 7, 2007).
  • "What to Consider When Making a Voluntary Self-Disclosure," with Daniel Solomon, The Export Practitioner 21, no. 9 (September 2007).
  • "Unprecedented $100 Million Penalties In ITT Export Case," White Collar Crime 21, no. 9 (June 2007).
  • "Record Setting Penalty in ITT Case Shows Risks of Outsourcing for Defense Contractors," International Government Contractor 4, no. 4 (April 2007).
  • "Playing by the Rules in Export Controls and Sanctions" (Hughes Hubbard & Reed Client Seminar, Miami, FL, March 15, 2007).

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