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Rachel Small

Counsel

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Rachel Small brings more than 15 years of government, defense-industry, and private-practice experience advising clients on US and international export controls, sanctions, and national security regulatory matters. She counsels companies across the defense, aerospace, and technology sectors on compliance with the ITAR, the EAR, and OFAC sanctions regimes, offering practical, risk-focused guidance tailored to complex operational environments.

Rachel assists clients with internal investigations, voluntary disclosures, jurisdiction and classification analyses, and compliance program development. She regularly supports organizations in navigating multi-agency regulatory frameworks, managing cross-border technology and data issues, and addressing evolving global trade and national security risks.

Her government experience includes significant regulatory and enforcement roles in the United States and Australia. In the US, Rachel served with the Department of State’s Directorate of Defense Trade Controls (DDTC), where she worked on licensing, compliance, and enforcement matters involving defense articles, technical data, and defense services. Rachel also served as a Sanctions Enforcement Officer at the Department of the Treasury’s Office of Foreign Assets Control (OFAC), where she handled investigations involving U.S. economic sanctions laws.

In Australia, Rachel held several legal and policy roles, including serving as a Senior Attorney in the International Criminal Law Division of the Australian Attorney-General’s Department. Her cross-jurisdictional experience provides a well-rounded international perspective on regulatory interpretation, enforcement priorities, and practical compliance governance.

Most recently, Rachel served as Assistant General Counsel for Global Trade at Leidos, advising a multinational defense contractor on export controls, sanctions compliance, and national security regulatory obligations.

She holds a Master of Laws in International Law and is admitted to practice in both New York and Australia.

 

Admissions & Certifications

Australia
New York

 

Thought Leadership
Publications

Co-Author, International Trade Industry Update, Trade Compliance Alert: ITAR Proposed Rule to Revise Definition of “Defense Services” + Associated Licensing Requirements, Fluet, August 2024

Co-Author, International Trade Industry Update, Trade Compliance Alert: Proposed ITAR Exemption for U.S.-UK-Australia Defense Trade Unveiled, Fluet, May 2024

Co-Author, 10 Key Considerations for GovCon Employers When Staffing Contracts, Fluet May 2023

 

Education

LL.M., International Law, The University of Sydney

Graduate Diploma in Legal Practice, Australian National University

LL.B., Macquarie University

Diploma of Education, Macquarie University

B.A., Macquarie University
 

Prior Experience

Assistant General Counsel, Global Trade, Leidos

National Security Attorney, Fluet

Policy Analyst (US Department of State), DNI (Delaware Nation Industries)

Regulatory and Multilateral Affairs Analyst (US Department of State), Muscogee International, LLC

Export Controls Project Manager (US Department of Homeland Security), BAI, Inc.

Sanctions Enforcement Officer, US Department of Treasury

Compliance Specialist, Enforcement Division, US Department of State, Directorate of Defense Trade Controls

Senior Attorney, Criminal Law Division, Attorney-General’s Department, Australia

EXPERTISE

Meet Our Team

Learn more about our professional's background and expertise.

Jon P. Yormick

Founder / Managing Member

Founder and Attorney with over 30 years of experience in international business and trade law. His practice often centers on sensitive investigations, self-disclosures, penalties, enforcement, compliance, and litigation involving antiboycott regulations, customs, export controls, economic sanctions, FCPA/antibribery, and government procurement.

Coraly Schreiber

Counsel

Bringing more than 22 years of federal government service and private practice experience, she advises clients on complex Customs and international trade matters. A former senior attorney with U.S. Customs and Border Protection, she is a recognized authority on enforcement actions, penalties, seizures, and regulatory compliance, and leads the Firm’s San Juan office as Counsel.

Pavit Arora

Associate

Specializing in international trade, with a focus on export controls, economic sanctions, and U.S. imports, she advises clients in sectors like aerospace, defense, automotive, and telecommunications. Originally from Massachusetts, she is based in the Firm’s Fort Lauderdale office.

Anne Brandon

Associate

Anne Brandon focuses her practice on Customs and international trade, helping clients reduce costs, ensure compliance, and navigate regulations. She advises on duty mitigation strategies—such as FTZs, First Sale, and Chapter 98 provisions—as well as classification, origin, and valuation issues under US trade laws and FTAs.

Caylan Fazio

Of Counsel

Caylan supports clients in the space, aerospace, and defense sectors by addressing their unique compliance challenges with practical, tailored solutions. A graduate of Cleveland State University College of Law, her research has focused on FAA launch licensing, international coordination on the moon, and public-private partnerships for spaceports.

Andrea J. Tommasini

Paralegal

A key part of the Firm since its inception, Andrea Tommasini joined its predecessor in the late 1990s. Over the years, she has managed a variety of substantive client matters and supported numerous attorneys, along with handling business development and administrative tasks.

Kathleen August

International Trade Advisor

A former Sr. Auditor and Team Leader at U.S. Customs & Border Protection, Kathleen August brings 34 years of government experience to her role as an International Trade Advisor. She helps businesses interpret complex trade regulations, enhance compliance programs, and identify opportunities for duty savings across multiple industries.

Jaime Robinson

International Trade Analyst

Provides strategic support on cross-border trade and manufacturing between the U.S. and Mexico, advising on Customs compliance, HTS classification, country-of-origin determinations, and technical process analysis across multiple high-technology sectors to ensure accurate and defensible compliance outcomes.