Adam M. Smith is a partner in the Washington, DC, office of Gibson Dunn and serves as co-chair of the firm’s international trade advisory and enforcement as well as the sanctions and export enforcement practice groups. He is an experienced international lawyer with a focus on international trade compliance and white-collar investigations, including federal and state economic sanctions enforcement, the Committee on Foreign Investment in the United States, the Foreign Corrupt Practices Act, embargoes, and export and import controls.

Chambers USA and Chambers Global consistently rank Smith as a leading attorney in “International Trade: Export Controls & Economic Sanctions.” In those publications, clients describe Smith as “a terrific resource for clients” and a “reassuring lawyer in a complex area of law.” Most recently, Legal 500 US 2024 named Smith a “Leading Lawyer” in “International Trade: Customs, Export Controls, and Economic Sanctions.” Global Investigations Review has named him to its “25 Most Respected Sanctions Lawyers in Washington, DC” list, which features individuals who work on the most significant cases. The Best Lawyers in America recognizes him for international trade and finance law. Who’s Who Legal regularly recognizes him as a thought leader for trade and customs, international sanctions, and in its “Global Elite Guide.”

Clients benefit from Smith’s experience in the Obama administration, where he was senior advisor to the director of the US Treasury Department’s Office of Foreign Assets Control (OFAC) and director for multilateral affairs on the National Security Council. At OFAC, he was instrumental in shaping and enforcing sanctions policies, briefing congressional and private sector leaders, conducting extensive international outreach, and negotiating complex agreements. On the National Security Council, he advised the president on international sanctions, coordinated inter-agency efforts, and developed strategies to counter corruption and promote asset recovery.

Smith has successfully represented a regional financial institution before OFAC and other agencies in responding to a subpoena following revelations of potentially sanctionable conduct and assisted the US branch of a foreign financial institution in successfully responding to multi-agency regulatory inquiries and examinations. He has ongoing sanctions representation for a major corporation addressing multi-agency civil and criminal enforcement. He advised the board of directors of major financial institutions in addressing sanctions governance shortfalls and assisted the bank in developing robust policies, procedures, and training protocols. He overhauled sanctions compliance oversight and processes at a major e-payments company and provides ongoing sanctions, anti-corruption, and anti-money laundering compliance advice to major financial institutions, Fortune 500 manufacturers, and insurers. Smith is retained by a Fortune 100 manufacturer to conduct an internal Foreign Corrupt Practices Act (FCPA) investigation and provided sanctions advice in the context of a proposed deal, and he has worked with a major manufacturer to obtain regulatory approvals for sale of products into high-risk jurisdiction and to manage ongoing licensing and compliance issues. Finally, he is retained by a major cybercurrency enterprise to develop compliance procedures and engage with regulators.

Clients, governments, academia, and other law firms regularly seek Smith’s advice. He is a prominent thought leader, and his analysis regularly appears in print and broadcast media, including in The Economist, The Wall Street Journal, The New York Times, The Washington Post, and on BBC and NPR. He is the author of three legal texts and dozens of articles and book chapters, has testified before the US Congress and the UK Parliament, and is a frequent presenter at industry, governmental, and academic conferences globally.

Smith is a 2006 magna cum laude graduate of Harvard Law School where he was a Chayes fellow, the recipient of the Laylin Prize for the best work in international law, and the senior editor of the Harvard International Law Journal. He graduated magna cum laude from Brown University in 1996 with a bachelor of arts in political science and economics, and a master of philosophy in politics from Oxford University in 1998 where he was the Seaton Scholar in Politics at St. Hugh’s College. Following law school, Smith served as a law clerk for the Honorable James Baker on the US Court of Appeals for the Armed Forces. Smith subsequently practiced for more than three years at a major international law firm in Washington, DC, where he advised clients on trade policy, national security, regulatory reform and risk, FCPA, and international investment. He has also held postings with the United Nations in New York, the World Bank and International Finance Corp. in Washington, DC, and abroad, and the Organisation de coopération et de développement économiques in France.