Darshak S. Dholakia
Partner | Washington, D.C.
Darshak S. Dholakia

Darshak S. Dholakia primarily advises on compliance with national security and international trade laws, including economic sanctions programs administered by the Office of Foreign Assets Control (OFAC), anti-money laundering (AML) provisions of the USA Patriot Act, the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws, and export controls (Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and the Part 110 and 810 nuclear export control regulations).

Mr. Dholakia regularly assists clients in proactively assessing and mitigating risks under these laws and developing practical solutions when problems arise.  He also regularly conducts internal investigations, develops compliance programs, oversees risk assessments, conducts due diligence for corporate transactions, obtains export control classifications, and interacts with government agencies in relation to compliance and enforcement-related proceedings.

Mr. Dholakia also advises clients in connection with transactions implicating national security reviews conducted by the Committee on Foreign Investment in the United States (CFIUS). He has represented foreign investors and acquirers and domestic sellers and targets in connection with many dozens of investment transactions.

Mr. Dholakia is co-author of the United States chapter of Global Legal Insights – Bribery & Corruption, a book covering bribery and corruption law in 27 jurisdictions that provides an overview of the law and enforcement regime, enforcement activity during recent years, issues relating to investigation and enforcement decisions, corporate liability and proposed reforms in the years ahead. Mr. Dholakia also has authored articles for the Global Trade and Customs Journal and the Anti-Corruption Report and has provided commentary for Bloomberg and Law360. He has been quoted in the Washington Post, Bloomberg, Los Angeles Times, The Register, Yahoo, and the Hindustan Times, among others.

In recognition of his significant work on pro bono matters, Mr. Dholakia has made the Capital Pro Bono Honor Roll numerous times, an initiative sponsored by the District of Columbia Court of Appeals and the Superior Court of the District of Columbia.

Prior to joining Dechert, Mr. Dholakia was an associate in the international trade and investment group of an international law firm. He also previously clerked in the United Nations Office of Legal Affairs.

  • Advising and conducting training sessions for investment advisers, mutual funds, and other financial services companies regarding compliance with economic sanctions, anti-bribery, and anti-money laundering laws.
  • Conducted a risk assessment and enhancement of the export control and sanctions compliance program of a multinational network infrastructure and cloud service provider company.
  • Advised a publicly-traded satellite technology company on compliance with global export control, sanctions, and anti-bribery laws.
  • Conducted anti-bribery investigations in various Latin American countries on behalf of a publicly-traded medical device company.
  • Represented senior officials of a publicly-traded high technology company in anti-bribery investigations by the U.S. Department of Justice and Securities & Exchange Commission.
  • Represented various sanctioned persons in connection with their designations under various sanctions programs.
  • Negotiated a settlement agreement with the U.S. Treasury Department related to violations of economic sanctions on behalf of a global travel services company.
  • Represented an Asian sovereign wealth fund before CFIUS in connection with multiple investments in U.S. companies.
  • Conducted a risk assessment and implemented related changes to the global anti-financial crimes compliance program of a major investment management firm.
  • Conducted an internal investigation in response to a whistleblower report alleging anti-bribery violations on behalf of a publicly-traded high technology company.
  • Conducting international trade compliance due diligence in connection with corporate transactions involving sellers and buyers in a broad range of industries, including the travel, manufacturing, financial services, and telecommunications sectors.
  • Advising various multinationals with respect to sufficiency of compliance policies and procedures and suggested improvements reflecting risk assessments and global best practices.
  • China: Comprehensive Analysis of Recent OFAC Guidance on China Risk Mitigation for Your Operations – and the Impact of China’s Retaliatory Measures — ACI Passport to Economic Sanctions Proficiency (February 13, 2023)
  • China: Navigating the Regulatory Web of Sanctions and Export Controls  ACI 18th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance (April 29, 2024)
  • Financial Services Risk Tolerances: The Newest Approaches to Managing Sanctions and Geopolitical Risk and Cross-Industry Lessons  ACI 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance (April 25, 2023)
  • Russia Sanctions and the Unique Challenges for Global Life Science Companies  ACI’s 18th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry (May 11, 2023)
  • “What’s Next: Key issues to Watch in 2023”  ACI New York Forum on Economic Sanctions (December 7, 2022)
  • Sanctions Update: “Hot Button” Sanctions Issues and What Lies Ahead for Global Business —  TRACE International (July 19, 2022)
  • New OFAC Guidance Clarifies Broad Interpretation of U.S. Prohibition on New Investment in Russia   Investment Company Institute, (June 9, 2022)
  • Update on New U.S. Sanctions Against Russia — Investment Company Institute, (May 19, 2022)
  • Cutting-Edge Strategies for Leveraging Innovation to Strengthen Your Sanctions Screening Processes — ACI 16th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance (May 5, 2022)
  • UK/EU/US Russia Sanctions Update and Comparisons — Investment Company Institute (March 25, 2022)
  • Impact of New Russia Sanctions on the Financial Services Industry — Investment Company Institute (March 4, 2022)
  • Russia Sanctions Update — Investment Company Institute, (February 28, 2022)
  • Deciphering More Country-Specific Sanctions Restrictions: Cuba, Venezuela, Syria, North Korea, Afghanistan, and Belarus  –  ACI’s Economic Sanctions Proficiency series (Feb. 16, 2022)
  • The potential impact of additional U.S. sanctions against Russia on the financial services industry — Investment Company Institute (Feb. 3, 2022)
  • Key Areas to Watch for the Next Six Months — 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance (Dec. 8, 2021)
  • Examining Whether U.S. Export Controls Align with the Laws of the World Trade Organization — Lexology webinar (Dec. 6, 2021)
  • Measuring the Effectiveness of Your Compliance Program: Compliance Lessons and Where Companies Go Wrong — ACI's 38th International Conference on the Foreign Corrupt Practices Act (Dec. 1, 2021)
  • China Sanctions: Ripple Effects and Responses — Institutional Investor's Litigation & Governance Trends for Asset Management Firms (March 9, 2021)
  • Impact of New US Sanctions on Publicly Traded Securities of Communist Chinese Military Companies — Mutual Fund Directors Forum (Jan. 13, 2021)
  • Additional Developments for China Military Company Sanctions — Investment Company Institute (Jan. 7, 2021)
  • Update on China Military Company Sanctions — Investment Company Institute (Jan. 4, 2021)
  • Sanctions Update: Communist Chinese Military Companies — Investment Company Institute (Dec. 21, 2020)
  • New CFIUS Regulations and the Impact on Private Equity Transactions — Investment Adviser Association (Dec. 16, 2020)
  • New Sanctions on Securities of Chinese Military Companies — Investment Company Institute (Nov. 24, 2020)
  • CFIUS and its Impact on Chinese Investment in the United States — Podcast #14, China Law and Practice (Aug. 14, 2020)
  • US National Security, CFIUS, and COVID-19, Podcast — Bribe, Swindle, or Steal (Apr. 15, 2020)
  • AML Considerations for Investments in Cannabis-Related Businesses — Practicing Law Institute (June 2020)
  • Trade and Investment as a Tool of Foreign Policy — New England Legal Foundation, Boston (June 12, 2019)
  • Hurricanes in the Caribbean: Recent Developments in Venezuela, Puerto Rico and More — Dechert Distressed Investing Forum, New York, NY (Oct. 18, 2018)
  • Russia Sanctions Briefing  — Dechert Russia LLC, Moscow (Feb. 1, 2018)
  • U.S. and Other Global Foreign Investment Controls on the Mining Sector — 63rd Annual Rocky Mountain Mineral Law Institute, Santa Fe, NM (July 21, 2017)
  • Implementation Day: Understanding the Impact of Changes to Iran Sanctions on Your Business — Dechert LLP, Washington, D.C. (Jan. 21, 2016)
  • US Nuclear Export Controls and Proposed Changes to the Part 810 Regulations — DC American Nuclear Society, Washington, D.C. (Feb. 7, 2013)
  • Anti-Corruption Compliance Concerns and Other Considerations for International Sales Activities — Medical Device Manufacturers Association Compliance Workshop, Waltham, MA (Nov. 1, 2012)
  • “Enhanced US National Security Measures Raise Risks for Cross-Border Activities,” The Legal Industry Reviews USA Vol. 1 (March 2023)
  • "Department of Justice Revises Policy on Voluntary Self-Disclosures of Sanctions and Export Violations," ABA Criminal Justice Section’s The State of Criminal Justice 2020 (July 2020).
Services Industries
    • Yale University, B.A., 2004, with Distinction
    • Columbia Law School, J.D., 2007
    • District of Columbia
    • New York
    • Gujarati
    • Hindi
    • Spanish
    • South Asian Bar Association
    • American Bar Association
    • American Society of International Law