Export Controls

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Export controls and sanctions regulations present significant challenges and potential compliance risks for global companies. The U.S. government regulates transfers of goods, technology, software, and other products and services to foreign destinations as well as to foreign persons within the United States and abroad. These controls are far reaching, extending to direct transfers of goods, technology, software, and services from the United States, "reexports" of certain U.S.-origin items and technology from one foreign country to another, and reexports of certain foreign-manufactured items containing U.S. content. They also apply to transfers of technology to foreign persons within the United States and U.S. persons working for foreign companies. Other governments have their own export control and sanction regulatory regimes, creating complex compliance obligations with practical and commercial implications for businesses, including problems with inventory management and shipping delays.

With lawyers across North America, London, and Brussels, Crowell & Moring's International Trade Group advises clients on the full range of laws governing exports and reexports of goods, technology, software, and services. In conjunction with our full-service international policy and regulatory affairs affiliate, C&M International, and our international network of experienced, knowledgeable local counsel, we assist clients in gaining access to markets beyond the United States and the European Union (EU), including Hong Kong, Israel, and Singapore, as well as across Central and South America. Our U.S. and Brussels trade practices are consistently ranked among the world's leading practitioners by Chambers USA and Chambers Global, which cite our work in numerous areas, including export controls and economic sanctions.

With respect to the EU and its 28 Member States, our European lawyers advise on legislation regarding export controls of dual-use and defense-related items, including intra-EU transfers of defense-related items and EU economic sanctions regimes. Our U.S. lawyers routinely train and counsel clients on compliance with the Export Administration Regulations (EAR) of the U.S. Department of Commerce governing commercial or "dual-use" items, the International Traffic in Arms Regulations (ITAR) of the Department of State governing defense articles and services, and sanctions and embargoes of the Office of Foreign Assets Control (OFAC) of the Department of the Treasury, which target specific countries and designated nationals. We also advise on controls implemented by other agencies, including the Department of Energy, the Nuclear Regulatory Commission, and the scope of foreign filing licenses under U.S. Patent and Trademark Office (USPTO) regulations. 

Our clients include a variety of large and small companies such as high-tech companies in the semiconductor, software, and software encryption industries, manufacturers in the aerospace and defense industry, producers and distributors of specialty chemicals, and providers of financial services and insurance. We also represent airlines and air freight forwarders, which are also subject to export controls and sanctions, and have unique compliance responsibilities and challenges as transportation providers. We know that our clients' needs, budgets, business models, and time frames vary, and our advice and compliance strategies are designed to meet each client's unique situation.

Our services include the following:

  • Advising on licensing requirements and preparing license and agreement applications
  • Performing internal investigations and assisting with voluntary disclosures
  • Performing compliance audits
  • Designing and implementing compliance programs
  • Performing jurisdictional assessments and preparing requests for commodity jurisdiction determinations
  • Assisting in self-classification of products and preparing requests for commodity classification requests
  • Performing export control/sanctions due diligence reviews related to proposed mergers and acquisitions
  • Representing clients in civil and criminal enforcement proceedings
  • Training on export control procedures and requirements

View More

"The Month in International Trade – April 2022," International Trade Bulletin (May 10, 2022). Contacts: Jeffrey L. Snyder, Frances P. Hadfield, Edward Goetz
Client Alert/Newsletter
Customs Ruling of the Week – Classification of Emergency Hammer (May 6, 2022). Authors: Frances P. Hadfield and Martín Yerovi.
"Global Mobility and Workforce Concerns During the Ukraine/Russia Conflict," International Trade Bulletin (May 6, 2022). Contacts: Nicole Janigian Simonian, Jackson C. Pai
Client Alert/Newsletter
"Takeaways on Balancing How to Maintain Open Investment Policy while Protecting National Security," American Conference Institute, Washington, D.C. (April 27, 2022). Speakers: Caroline E. Brown.
Continuing To Do Business In Russia Carries Risks, But So Does Decoupling, Lawyers Say Export Compliance Daily (April 25, 2022)
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"Global Data Transfer Developments: Taking the APEC CBPR System Global," International Trade Bulletin (April 22, 2022). Contacts: Robert Holleyman, Clark Jennings, Jeffrey L. Poston, Christopher D. Gundermann
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Sanctions Threaten To Cripple Russia’s Multibillion-Dollar Crypto Industry CNBC (April 22, 2022)
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Russia Sanctions Led American Express To Cut Financial Lifeline In Ukraine Wall Street Journal (April 22, 2022)
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Sanctioning An Ether Address Isn't Stopping Transactions CoinDesk (April 22, 2022)
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ITC Clears Path For Costly Duties On Chinese Snowblowers Law360 (April 22, 2022)
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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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