Troy Galan advises domestic and foreign clients on matters at the intersection of national security and international trade, with an emphasis on international transactions, government contracting, and related government and internal investigations. He counsels clients on the Committee on Foreign Investment in the United States (CFIUS), export controls, economic sanctions, foreign anti-corruption, and customs regulations. Leveraging his deep understanding of these practice areas, Troy assists industries such as defense, aerospace, and advanced technology companies in maneuvering the compliance requirements associated with government contracts, awards, and grants.
Previously, Troy served as a senior member of the legal team overseeing one of the largest corporate monitorships in U.S. history as part of the Department of Justice and Bureau of Industry and Security (BIS) settlement agreements.
Troy serves on Snell & Wilmer’s Export Compliance Committee and is a regular contributor to the firm’s International Industry group’s Global Connection newsletter.
CFIUS
Troy’s national security practice focuses on advising a wide range of clients, from multinational corporations to emerging companies, in navigating the regulatory aspects of foreign investments, such as complex M&A deals and startup funding. He assists buyers and sellers in understanding and mitigating the risks associated with investments, acquisitions, divestments, transfers, and other corporate transactions.
He has experience analyzing pre-transaction risks, conducting due diligence reviews, negotiating agreements, preparing voluntary and mandatory filings to the Committee, and responding to CFIUS inquiries.
Export Controls, Economic Sanctions, & Foreign Anti-Corruption
Troy evaluates jurisdiction, classification, and licensing requirements under the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and Office of Foreign Assets Control (OFAC). He also prepares license applications, commodity jurisdiction (CJ) requests to the Department of State, and commodity classifications to the Department of Commerce.
By conducting risk assessments of business operations, Troy assists clients in establishing or enhancing policies, procedures, and assessing compliance programs for adherence to international trade regulations such as the Foreign Corrupt Practices Act (FCPA). He also provides guidance on “know-your-customer” and due diligence best practices to negotiate agreements and contractual safeguards for transactions of all sizes. Additionally, Troy frequently provides training on these compliance areas.
Customs
Troy advises clients on complying with Customs and Border Protection (CBP) regulations and resolving customs violations. He has experience representing importers and exporters during CBP inquiries, responding to notices of violation, and related administrative proceedings.
Troy also counsels clients regarding country of origin analyses and tariff and duty determinations. As part of his customs practice, he assists clients in requesting CBP rulings, seeking beneficial tariff treatment for onshoring and nearshoring operations, and establishing Foreign Trade Zones in the United States.
U.S. Government Contracts
With his experience in foreign investments and other international trade matters, Troy counsels clients on key regulatory and compliance requirements under the Federal Acquisition Regulations (FARs) and Defense Federal Acquisition Regulation Supplement (DFARS) related to U.S. Government bids, contracts, and other federal funding opportunities.
Troy also helps clients in compliance matters involving the Buy American Act, Free Trade Agreements Act, Buy America regulations, and related procurement agreements involving foreign supply chains.
Government and Internal Investigations
Troy’s experience as a former senior member of the legal team responsible for one of the largest corporate monitorships in U.S. history uniquely qualifies him to assist clients in handling U.S. Government enforcement cases. With extensive experience preparing confidential reports for federal law enforcement agencies, he provides clients with valuable insights to resolve violations and mitigate penalties while addressing business and national security concerns.
Finally, Troy has experience in overseeing internal investigations for multinational corporations. Having led internal inquiries and legal audits across Asia, Europe, Latin America, and the Caribbean, he assists companies in aligning with U.S. laws and regulations. Troy’s approach emphasizes the importance of thorough internal investigations while minimizing disruptions to day-to-day operations and unwanted publicity.
Spanish
CIFUS
Exports
International Trade
U.S. Government Contracts
Investigations