Export Controls

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The United States maintains a complex system of controls over the export of U.S. goods and technology. The State Department — in the International Traffic in Arms Regulation (ITAR) — controls the export of any item, technology, or service that it places on the U.S. Munitions List.

The Department of Energy has authority over nuclear related items. The Department of Treasury — through the Office of Foreign Assets Control (OFAC) — implements and administers sanctions and embargoes against specific countries such as Cuba, Iran, Iraq, and former country Yugoslavia.

Finally, the Department of Commerce — in the Export Administration Regulation — has licensing authority over so-called "dual use" items, but these regulations potentially reach virtually any product or service that is to be exported (or re-exported from a foreign location).


Our experience extends across these various regulatory schemes. Just as important, we have experience with many of the industries most affected by these regulations:

  • Aerospace and defense
  • Satellite and launch services
  • Information technology
  • Telecommunications
  • Research labs
  • Manufacturing/capital equipment

Counseling, Investigations, and Litigation

We have counseled clients in these and other industries from, literally, on-the-spot questions to full-scale compliance reviews, to litigation of administrative penalty cases.

Representative Engagements

  • Defended a major U.S. aerospace company against State Department administrative charges arising from the alleged unauthorized transfer of technical data and performance of defense services in connection with satellite launch in China
  • Counseled foreign manufacturer on reach of OFAC regulations in controlling domestic subsidiary's technology needed if foreign affiliate were to obtain contract with Iran; counseled a telecommunications company on deemed export that would occur in using foreign national employees in work involving controlled technologies
  • Investigated potential violations, identified corrective actions, and prepared comprehensive voluntary disclosure to the Department of Commerce for manufacturer of dual use aerospace product

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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