Export Controls | Blank Rome LLP

Overview

We advise clients in all aspects of export controls, including matters arising under the Export Administration Regulations (“EAR”) administered by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the International Traffic in Arms Regulations (“ITAR”) administered by the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”).

We provide the following services for clients on export control matters:

Counseling on cross-border transactions
Product and technology classification analysis
Preparation and submission of licensing, commodity jurisdiction, and classification requests
Compliance audits
Development of compliance programs and provide export compliance training
Representation of parties in connection with subpoenas, investigations, and enforcement proceedings
Preparation and submission of voluntary and directed disclosures to BIS and DDTC
Advice on issues relating to the U.S.-China strategic trade competition
Industry-specific advice, including with respect to aerospace and defense, semiconductors and electronics, emerging technologies, telecommunications, cybersecurity, sensors and lasers, chemicals, and materials processing

Advice on compliance with anti-boycott regulations and related reporting requirements

Key Contacts

Related Services

Experience

Advised a non-U.S. server manufacturing company on navigating the intricate jurisdictional challenges and substantive prohibitions under U.S. semiconductor export controls.
We advise a large German company regarding export controls applicable to semiconductor manufacturing equipment.
We provide export controls advice to a multinational manufacturer of advanced materials and semiconductor manufacturing equipment.
Conducted an export controls internal investigation for a U.S. firmware developer with respect to its sales in China, submitting a voluntary disclosure and successfully securing a closeout of the matter without a penalty.
Advise large auto manufacturer regarding geopolitical risk issues, export control classification of its technology, implementation of its compliance program, and day-to-day counseling matters.
Conducted a comprehensive export controls compliance audit across the three subsidiaries of a U.S. defense contractor mainly focused on the aerospace and space industries, including site visits throughout the United States and 30+ interviews.
Assisted a company in responding to a subpoena and submitting voluntary disclosures to regulators regarding its exports of defense articles to Ukraine in support of Ukraine.
Advise a U.S. helicopter transportation company regarding export control issues related to its provision of search and rescue services to foreign governments and other parties outside the U.S.
Advised a European multinational company in its acquisition of a medical device company, including diligence of the target company’s exposure to certain export controls and economic sanctions risks.
Conducted an export controls internal investigation for a U.S. cybersecurity company.
Advised semiconductor foundry / government contractor in acquisition by an investor, conducting comprehensive export control classification assessment of the company’s products and liaising with buyer’s counsel.
Represented a major global petrochemical transportation and logistics company before the U.S. Department of State in connection with the shipment of Kurdish petroleum products across Iran for export.
Provided ongoing export control advice to a Fortune 500 company manufacturing military vehicles regarding the application of U.S. export control laws to numerous different transactions.
Advised a satellite software company on the application of U.S. export control laws to the sale of satellite software to satellite operators in numerous countries.
Advised a U.S. company engaged in research and development of alternative energy sources regarding the application of export control laws on the military application of their products, including joint ventures with foreign manufacturers.
Advised a U.S. company with a foreign subsidiary that manufactures defense articles on the structuring of company operations to comply with U.S. export control laws.
Advised a U.S. subsidiary of an Italian defense industry company regarding the application of U.S. export control laws related to the import and export of defense articles.
Advised a Canadian software company regarding application of U.S. re-export control laws on software with U.S.-controlled content.
Assisted a Fortune 500 manufacturing company in connection with due diligence and internal investigations, as well as the preparation of voluntary disclosures to the U.S. Department of Commerce and the U.S. Department of State related to unauthorized exports of technical data and controlled items.
Prepared technical assistance agreements for a U.S. subsidiary of an Italian weapons manufacturer for U.S. Department of State authorization to export technical data and defense services in connection with establishing a U.S. manufacturing facility and in participating in various foreign military sales programs, including obtaining various licenses from the ATF.
Assisted a Fortune 500 company in the preparation and filing of licenses and technical assistance agreements with the U.S. Department of State and the U.S. Department of Commerce to authorize the export of manufactured products and technical data to numerous foreign countries.
Conducted an export controls internal investigation for a U.S. cybersecurity company.
Conducted export controls compliance audits in Saudi Arabia and Spain for a large aerospace and defense company.
Conducted a comprehensive export controls compliance audit across the three subsidiaries of a U.S. aerospace and defense company.
Conducted comprehensive compliance policy review, export control classification exercise, and supply chain review for a large European manufacturer.
Advised semiconductor foundry / government contractor in acquisition by an investor, conducting comprehensive export control classification assessment of the company’s products and liaising with buyer’s counsel.