Sam Witten, a former senior legal and policy official with the US Department of State, helps private clients and foreign governments address complex multinational issues. His practice includes policy development, counseling, advocacy, litigation, and arbitration. His background as a former senior US official working on foreign policy and economic issues helps him provide clients practical and strategic insights into governmental decision making and enables him to develop creative solutions to complex international issues.

Mr. Witten's practice spans trade and investment issues, corporate compliance, international arbitration, and national security law. He helps companies develop and implement compliance programs related to export controls, trade sanctions, and anti-corruption statutes. He represents clients in arbitrations at the International Centre for Settlement of Investment Disputes and under the North American Free Trade Agreement. His practice also includes international law enforcement cooperation, economic issues, corporate social responsibility, and public international law.

Before joining the firm, Mr. Witten served at the US State Department as Deputy Legal Adviser (equivalent to Deputy General Counsel) and Principal Deputy Assistant Secretary of State. As Deputy Legal Adviser, the top career legal position at the State Department, he supervised the Department's legal work on East Asian and Pacific matters; trade, investment and intellectual property issues; human rights; environmental matters; international law enforcement cooperation; and Latin American matters. As Principal Deputy Assistant Secretary of State, he managed the US Government's worldwide refugee relief programs, including heading the State Department's diplomacy on these issues at the UN and other international organizations. Earlier roles at the State Department in a 22-year career included Assistant Legal Adviser for Law Enforcement and Intelligence (where he negotiated US law enforcement treaties around the world) and Acting Director of the Office of War Crimes Issues. Mr. Witten earlier was a Trial Attorney in the Foreign Commerce Section of the Justice Department's Antitrust Division, specializing in transnational antitrust issues and investigations.

Mr. Witten's pro bono work includes service on the Advisory Board of Kids in Need of Defense (KIND) and the Board of Advocates of Human Right First.


  • Multinational company in an internal investigation concerning potential Foreign Corrupt Practices Act violations which was self-reported to the Securities and Exchange Commission and the US Department of Justice.
  • Corporate managers in FCPA training programs conducted in Asia, Latin America, Europe, and Africa.
  • Investors in reviewing target company internal controls of target companies during due diligence in mergers and acquisitions.
  • US wood importers on compliance with Lacey Act and CITES.  
  • US companies and businesses on US economic sanctions, including as outside counsel to the International Wood Products Association.

  • US companies in audits of defense trade manufacturing and research facilities in the US and abroad under a US Department of State Consent Agreement.
  • US Government contractors on interpretation and implementation of new Foreign Acquisition Regulation on human trafficking.
  • SEC filers with compliance with Dodd-Frank SEC reporting rules on conflict minerals.


President Trump's Mexico City Policy: An Expansion of Restrictions on Foreign Aid
Understanding the US Ban on Importing Forced Labor Goods
Consumer Protection Law360, Food & Beverage Law360, International Trade Law360, Product Liability Law360, Public Policy Law360, Retail & E-Commerce Law360
Understanding the US Ban on Importing Forced Labor Goods
Managing FCPA and Corruption Risks in Third-Party Relationships
Arnold & Porter Kaye Scholer LLP
Trump Administration Issues New Sanctions on Persons Supporting Iran’s Ballistic Missile Program and Terrorism; OFAC Enforcement Continues


Latin Lawyer 250
Pro Bono (2017)
Presidential Meritorious Executive Awards
State Department Superior Honor Awards


  • JD, Columbia Law School, 1983, James Kent Scholar
  • BA, University of Maryland, 1979, magna cum laude
  • District of Columbia
Government and Military Service
  • Principal Deputy Assistant Secretary of State for Population, Refugees, and Migration: Supervised the US Government’s international relief efforts for refugees, including resettlement of refugees into the United States, and managed an annual refugee relief budget of over US$1.5 billion.

  • Deputy Legal Adviser (equivalent to Deputy General Counsel): Supervised State Department legal work in economic and business affairs (including economic sanctions); law enforcement and intelligence; international oceans, environmental and science affairs; human rights and refugees; Western Hemisphere affairs; and East Asian and Pacific affairs.

  • Acting Director, State Department Office of War Crimes Issues: Responsible for negotiating the return of detainees from Guantanamo, Cuba, to their countries of nationality.

  • Assistant Legal Adviser for Law Enforcement and Intelligence: Chaired US delegations in law enforcement treaty negotiations and supervised the US government's international extradition program; supported the US Justice Department's international investigations and prosecutions; represented the US Government in public hearings on nearly 40 law enforcement treaties.

  • Legal Counsel to State Department Office of Counterterrorism.

  • Chairman of US delegation at United Nations negotiation of the International Convention for the Suppression of Terrorist Bombings.

  • Staff Director, US interagency team, in arbitration with the United Kingdom over excessive charges imposed on US airlines at London’s Heathrow Airport.

  • Legal Counsel to US delegations in international human rights treaty negotiations and civil aviation agreements.

  • Executive Council, American Society of International Law

    • Co-Chair, 2015 ASIL Annual Meeting
  • Adviser, American Law Institute's Restatement Fourth of the Foreign Relations Law of the United States

  • Member, International Law Section, DC Bar Association

  • Past Chair, DC Bar Association Public International and Criminal Law Committee

  • Member of Board of Governors and Past President, Washington Foreign Law Society

  • Board of Advocates, Human Rights First

  • Advisory Board, Kids in Need of Defense (KIND)

  • Past Member of Board of Directors, Women's Refugee Commission

  • Past Officer and Member of Board of Directors, District of Columbia Jewish Community Center

  • President, Kol Shalom Congregation, Rockville, MD


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