Export Controls & Sanctions

The firm represents exporters, technology companies, and foreign businesses in matters arising under the Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), the economic sanctions programs of the United States, and the Foreign Corrupt Practices Act (FCPA). It regularly appears before the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of State’s Directorate of Defense Trade Controls (DDTC), the Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the Census Bureau. Much of this work concerns the extraterritorial reach of U.S. controls, and the firm advises European and other non-U.S. companies on when, and how, U.S. rules apply to their products and transactions.

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Categories of representation include but are not limited to:

  • Commodity Jurisdiction (CJ) Determinations and Classification (CCATS) Requests
  • Export Classification, including Encryption and Emerging Technology Items
  • License Determinations, Applications, and Management
  • Reexports, Transfers, and the Foreign Direct Product Rules
  • Deemed Exports and Technology Transfer
  • Entity List, Denied Party, and Restricted Party Screening and Delisting
  • Russia, China, and Other Country-Specific Controls
  • Embargoes and Economic Sanctions
  • ITAR Registration, Agreements, and Change-of-Ownership Notifications
  • Voluntary Self-Disclosures to BIS, DDTC, and OFAC
  • Antiboycott Compliance
  • Foreign Trade Regulations, Census, and AES Compliance
  • Anti-Corruption Compliance (FCPA)
  • Export Controls Due Diligence in Mergers and Acquisitions
  • Export Compliance Programs, Manuals, Audits, and Training