Economic Sanctions and Export Control
Sanctions Lawyers and Solicitors provides expert legal support in export control compliance under the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), the EU Dual-Use Regulation, and the UK Export Control Order 2008.
We specialize in U.S. sanctions (Office of Foreign Assets Control, OFAC), U.K. sanctions (Office of Financial Sanctions Implementation, OFSI), and EU sanctions (Council of the European Union/European Commission) across various high-risk jurisdictions certain countries, including Russia, Belarus, Cuba, Venezuela, Iran, and others.
Sanctions Lawyers and Solicitors provides expert legal support in export control compliance under the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), the EU Dual-Use Regulation, and the UK Export Control Order 2008.
We specialize in U.S. sanctions (Office of Foreign Assets Control, OFAC), U.K. sanctions (Office of Financial Sanctions Implementation, OFSI), and EU sanctions (Council of the European Union/European Commission) across various high-risk jurisdictions certain countries, including Russia, Belarus, Cuba, Venezuela, Iran, and others.
Our services include advising on OFAC licenses (including both OFAC General Licenses and OFAC Specific Licenses), conducting detailed counterparty due diligence, and assisting in the establishment of comprehensive compliance and Anti-Money Laundering (AML) programs.
With continuous monitoring of sanctions regimes and export control frameworks, we enable rapid responses to changes affecting restricted sectors, such as energy, finance, and high technology.
Dual-Use Products
Dual-Use Products, under EAR (15 CFR 730–780), regulated by the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce, encompass goods, software, and technology that can serve both civilian and military purposes, including the development of weapons of mass destruction (WMD). Dual-use items are generally divided into three categories:
(a) Commercial goods and technologies that can be adapted for military use or in the context of WMD;
(b) Items included on the Wassenaar Arrangement Munitions List (WAML) or the Missile Technology Control Regime (MTCR) that have commercial significance and fall under EAR;
(c) Purely commercial items controlled to prevent misuse for unauthorized or prohibited purposes.
The EAR applies to any goods requiring control and not under the jurisdiction of other U.S. agencies or explicitly excluded from the regulation (15 CFR 734.3 of EAR). The control framework is detailed in the Commerce Control List (CCL), which regulates dual-use products based on technical specifications, end-users, and destination countries. EAR 15 CFR 734.2 outlines the items, persons and activities subject to EAR, emphasizing that controls are aimed at maintaining a balance between innovation and security.
Dual-use control is a complex legal process to ensure compliance with U.S. regulatory authorities, requiring a rigorous approach and professional legal support.
The following presents an in-depth overview of the specialized legal services sanctions lawyers and solicitors provides in the domain of Dual-Use Products and Technology:
(a) Quantum Computing and Encryption Technologies
Formulated strategic export control frameworks for quantum computing entities, addressing complex classifications under EAR and ITAR for dual-use technologies, and successfully securing BIS authorizations for international collaborations involving quantum encryption methodologies.
(b) Semiconductor and Telecommunications Compliance
Assisted a prominent semiconductor manufacturer in navigating the stringent export controls imposed on advanced-node semiconductor technologies to China, facilitating BIS licensing and ensuring rigorous compliance with U.S. export control laws and policies pertaining to high-performance integrated circuits.
Provided comprehensive counsel to a telecommunications provider on export compliance for encryption-based dual-use technologies, including obtaining BIS and OFAC approvals for the international deployment of cryptographic modules, and addressing ECCN 5A002 and 5D002 compliance for 5G infrastructure.
(c) Chemical and Biotechnology Risk Management
Conducted risk assessments and devised mitigation frameworks for a multinational logistics company dealing with Schedule 1 and 2 chemical precursors, ensuring alignment with EAR, EU Dual-Use Regulations, and UK Strategic Export Controls.
Represented a biotechnology company in the submission of voluntary self-disclosures related to export violations concerning CRISPR-Cas9 technologies classified under ECCN 1C353, coordinating effectively with BIS and DHS to secure a favorable resolution.
(d) UAV and Autonomous Systems Export Compliance
Provided strategic advisory services to an AI-driven UAV manufacturing firm regarding dual-use export restrictions on machine vision technologies, ensuring comprehensive compliance with both EAR (ECCN 9A515) and ITAR amidst heightened regulatory scrutiny of autonomous systems.
Drafted and implemented export compliance programs for a manufacturer of specialized drones, integrating BIS regulatory mandates with Department of Defense directives to facilitate operations across the MENA region in light of increasing regional and national security interests and dynamics.
(e) Defense and High-Precision Machinery Compliance
Orchestrated a coordinated defense for a major electronics corporation under investigation by BIS, DOJ, and DHS for alleged export violations involving advanced semiconductor technologies, addressing concerns regarding reexports and diversion to embargoed destinations.
Executed export compliance audits for a precision engineering firm, focusing on ITAR-controlled high-precision machinery susceptible to military adaptation, and conducted specialized training for key personnel to ensure adherence to both BIS and ITAR regulations.
(f) Energy Storage and Advanced Materials Compliance
Assisted a renewable energy corporation in the self-classification and formal classification of advanced energy storage systems under ECCN 3A991, with an emphasis on dual-use applicability in grid resilience and military deployment contexts.
Advised an international consortium on compliance with re-export regulations for advanced composite materials employed in both civilian aircraft and UAV applications, navigating EAR Part 744 provisions and multilateral export control obligations for restricted carbon fiber materials.
(g) AI Hardware and Optics Export Control
Conducted a comprehensive export risk analysis for an AI hardware manufacturer, evaluating end-use and end-user risks for deep learning accelerators categorized under ECCN 4A994, and secured BIS authorizations for exports to regions subject to increased scrutiny.
Developed intricate compliance protocols for an advanced optics company to manage “deemed exports” involving foreign nationals, ensuring strict compliance with ITAR and EAR regulations for optical sensor technologies critical to national security.
(h) High-Performance Computing Export Negotiations
Represented a client in negotiations with BIS regarding the export of high-performance computing units categorized under ECCN 4A003, with dual-use applications spanning defense and advanced scientific research, securing the necessary authorizations amidst evolving regulatory controls over high-performance computing capabilities.
Economic Embargoes and Sanctions
Sanctions Lawyers and Solicitors provides legal support to clients both in the USA and globally on matters related to U.S. embargoes and sanctions administered by the OFAC. We offer services specifically focused on high-risk jurisdictions, including Russia, Belarus, Cuba, Venezuela, Iran, and other countries subject to OFAC sanctions. Our services encompass OFAC Compliance, OFAC Licensing, OFAC SDN List Removal, Release of Blocked Funds, and Anti-Money Laundering (AML) Compliance. We also work with U.K. sanctions and EU sanctions.
Our Expertise
Sanctions lawyers and solicitors provides legal services in international trade and export control. Our strengths include expertise in the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), EU Dual-Use Regulation, Council Regulation (EC) No 428/2009, Regulation (EU) 2019/125, UK Export Control Act 2002, and Export Control Order 2008.
We develop internal compliance programs to meet the requirements of OFAC, EU Sanctions Regulations, and UK Sanctions Regulations.
Our lawyers conduct internal investigations and representing clients before OFAC, OFSI, BIS, DDTC, HMRC, the EU Commission, and other regulatory bodies, and advise on export control and sanctions matters across multiple jurisdictions.
We ensure compliance for your operations under:
· EAR (Export Administration Regulations)
· ITAR (International Traffic in Arms Regulations)
· EU Dual-Use Regulation
· UK Export Control Order 2008
· Trade and economic sanctions administered by OFAC, EU Sanctions, and UK Sanctions
Contact an Economic Sanctions and Export Control Lawyer
Safeguard your business against legal risks associated with international sanctions and export controls. Our team of OFAC attorneys offers professional support to ensure compliance with sanctions and government export control regulations, minimize legal and financial risks, and protect your assets and reputation.
Contact us to receive expert legal advice, assistance and a tailored compliance strategy that secures the steady growth of your business amid complex sanctions and export control regulations.
