Export Controls

Overview

We have a unique capability to provide the full spectrum of representation and counseling in the field of US export controls, including economic embargoes and trade sanctions, general export controls, technology transfer restrictions, and anti-boycott regulations. We have significant experience advising on matters arising under the US Office of Foreign Assets Control (OFAC) sanctions programs, Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) US Antiboycott Regulations, and other US and international laws and regulations governing trade, payments, and investment transactions.

We help our clients to develop compliance programs, conduct audits and internal investigations, and facilitate compliance in connection with business transactions. We also advise US exporters on technology transfer issues and compliance and licensing matters relating to controlled technologies, for example (i) product and technology classifications; (ii) commodity jurisdiction requests; (iii) export and re-export licenses and license exceptions; (iv) technical assistance agreements and similar agreements under the ITAR; (v) compliance programs; (vi) “deemed” exports and related immigration and employment matters; and (vii) conflicts with foreign laws. We also provide representation before US Government agencies, including voluntary disclosures and export control enforcement matters.

Our clients include companies in the logistics and transportation, software, pharmaceutical and medical device, manufacturing, distribution, and education industries.

Experience

  • Advised U.S. software as a service company in connection with export classification and encryption registration of main service offering, and license application to export service to international humanitarian non-governmental organization in Syria

  • Counseled U.S. logistics software developer on facilitation risk under U.S. sanctions and embargo programs associated with service model, and filed export license request to Office of Foreign Assets Control

  • Advised U.S. biopharmaceutical company by auditing of its distribution network and implementing its U.S. export control compliance policy and program

  • Developed an export control compliance program for Texas liberal arts university

  • Designed U.S. export compliance and anti-money laundering programs for global payments processing company

  • Advised U.S. defense articles manufacturer on deemed export issues, and made license filings to employ foreign nationals in positions requiring disclosure of controlled technical data

  • Advised U.S. manufacturer of defense articles and provider of defense services on sales to Turkey and Saudi Arabia, including FCPA and U.S. export control compliance in connection with such transactions

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