Export Controls Regime Change
Regulations on exports are administered in the U.S. by over a dozen federal agencies, and infractions can have implications across all aspects of company operations. These challenges multiply for those operating in the context of other export control regimes, whether shipping or transferring goods, technology, and services across international borders or engaging in global M&A activity. Keeping track of changing regulatory demands, Kilpatrick Townsend’s attorneys assist clients in a broad range of industries, including education, technology, and health care in reviewing, revising, and strengthening internal controls to identify and prevent export violations.
Finding & Fixing
Our attorneys help clients develop robust export control compliance programs and assess current programs to uncover and mitigate vulnerabilities, in particular those related to countries sanctioned by the United States. We also advise on whether certain products or data are subject to laws, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations, and have specific experience in preparing commodity jurisdiction requests to determine which are subject to ITAR. Our legal team frequently provides training to employees at all levels on identifying potential export control issues.
When regulators allege wrongdoing and clients come under scrutiny, we can ably conduct internal investigations and prepare voluntary and mandatory disclosures to relevant agencies, including the U.S. Department of Justice, U.S. Treasury, the U.S. Department of Commerce, the Nuclear Regulatory Commission, Immigration and Customs Enforcement, and U.S. Attorney’s Offices in single and multi-agencies actions. Our attorneys have particular expertise advising on potential and actual sales in high-risk jurisdictions, such as Russia, Libya, Cuba, Sudan, Venezuela, and numerous countries in the Middle East.