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Maria Alejandra (Jana) del-Cerro

Partner

mdel-cerro@crowell.com
Phone: +1 202.624.2843
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring's Washington, D.C. office. She is a member of the firm's International Trade Group.

Jana counsels clients with respect to U.S. export controls and economic sanctions issues, with a focus on technology transfers. She provides transactional counseling, classification and commodity jurisdiction analysis, and M&A due diligence and related regulatory submissions. She also represents clients with respect to voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury.   

As part of her practice, Jana regularly:

  • Analyzes and advises U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, or hardware.
  • Performs jurisdictional and classification analyses under the ITAR and EAR, including drafting and submission of CJ and CCATS requests.
  • Develops and/or reviews U.S. export and sanctions compliance programs.
  • Represents clients with respect to voluntary self-disclosures to the Departments of State, Commerce, and Treasury, as well as EAR 764.5 waiver requests.
  • Performs M&A trade due diligence for both buy side and sell side clients, specifically on issues related to compliance with U.S. export controls and sanctions programs.
  • Counsels ITAR-registered companies on M&A regulatory requirements (60-day and five-day notices to DDTC under the ITAR) and transfer of DDTC and BIS authorizations.

Representative Matters

  • Regularly performs encryption classification analyses, submits commodity classification requests, oversees submission of license applications, and counsels on compliance with Department of Commerce encryption reporting requirements for Fortune 500 and Fortune 100 software and technology companies.
  • Regularly counsels large multinational software developers with respect to cross-border sales of software and the provision of cloud-based software services in compliance with U.S. export controls and sanctions laws, and successfully obtained Department of Commerce export licenses to support non-U.S. customer activity.
  • Developed global sanctions and export compliance programs for distributed database technology company, including procedures for determining applicability of U.S. encryption controls and for controlling technology and source code transfers.
  • Represented Fortune 100 information technology company in voluntary disclosure to the Department of Commerce for unauthorized exports of U.S. origin software.
  • Assisted international consulting and professional services company with classification of cyber security software solutions, with a focus on USML Category XIII(b) and encryption controls under the EAR, and drafted tailored compliance policies and training.
  • Prepared commodity classification request for forensic software company, and prepared related voluntary disclosure and waiver request to BIS.
  • Analyzed export classification and submitted commodity jurisdiction requests for defense simulation, training, and modeling software.
  • Analyzed export classification of multi-axis rate tables and prepared successful commodity classification request for reclassification of rate tables and related technology, and provided general export compliance counseling regarding exports of rates tables in compliance with EAR Part 744 restrictions.
  • Developed export compliance program for international methanol and petrochemical manufacturers with U.S. operations, and provided counseling on compliance with U.S. export and sanctions requirements.

Jana received a B.A. in history from the University of Virginia. She graduated with honors from the American University's Washington College of Law and received an M.A. in international affairs from the School of International Service. 

Education

  • University of Virginia, B.A., history (2004)
  • American University Washington College of Law, J.D. (2008)
  • American University School of International Service, M.A., international affairs (2008)

Affiliations

Admitted to practice: District of Columbia, Virginia

View More

"US Export Controls and Hong Kong – Change Underway," International Trade Bulletin (July 2, 2020). Contacts: Maria Alejandra (Jana) del-Cerro, Jeffrey L. Snyder, Robert Clifton Burns, Chandler S. Leonard, Brian McGrath
Client Alert / Newsletter
CFIUS Focuses On Chips, Lawyers Say; Expert Seeks Balanced US Approach To China Communications Daily (June 25, 2020)
Media Mentions
"China in the Crosshairs: An Overview of the U.S. Approach to Mitigating National Security Concerns," Crowell & Moring Webinar (June 23, 2020). Presenters: Caroline E. Brown, Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, David R. Stepp, Gail D. Zirkelbach, Erik Woodhouse, Stephanie L. Crawford, Chandler S. Leonard, and Andrew Blasi.
Speech/Presentation
"BIS Adds Australia Group Decisions to Commerce Control List," Crowell & Moring's International Trade Law (June 18, 2020). Authors: Maria Alejandra (Jana) del-Cerro, Chandler S. Leonard and Edward Goetz.
Publication
"DDTC Requests Comments on its Temporary Suspensions, Modifications, and Exceptions to the ITAR Due to COVID-19," Crowell & Moring's International Trade Law (June 17, 2020). Authors: Maria Alejandra (Jana) del-Cerro, Chandler S. Leonard and Edward Goetz.
Publication
"Introducing the Export Controls Classroom," Government Contracts Bullet Points (June 4, 2020). Contacts: Maria Alejandra (Jana) del-Cerro, Chandler S. Leonard
Client Alert / Newsletter
"CFIUS Expands Types of Transactions Subject to Pre-Closing Mandatory Declarations," Government Contracts Bullet Points (June 1, 2020). Contacts: Adelicia R. Cliffe, Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley
Client Alert / Newsletter
"BIS Adds 33 Chinese Companies to the Entity List," Crowell & Moring’s International Trade Law (May 29, 2020). Authors: Maria (Jana) del-Cerro and Chandler S. Leonard.
Publication
"BIS Creates a Special "Direct Product" Rule for Huawei," International Trade Bulletin (May 18, 2020). Contacts: Maria Alejandra (Jana) del-Cerro, Alan W. H. Gourley, Jeffrey L. Snyder, Chandler S. Leonard
Client Alert / Newsletter
"Commerce Announces EAR Rule Change to Further Target Huawei’s Access to U.S. Technologies," Crowell & Moring’s International Trade Law (May 15, 2020). Authors: Alan W. H. Gourley, Jeffrey L. Snyder, Maria Alejandra (Jana) del-Cerro and Edward Goetz.
Publication

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