U.S. export laws have broad extraterritorial effect and almost always apply to U.S. individuals and U.S. companies, including their foreign offices and branches, anywhere in the world and impact transactions with non-U.S. to parties to their transactions.

Our Firm has significant experience handling export compliance and import issues arising in the context of cross-border transactions, including:

OFAC

Sanctions

Country-specific trade and economic sanctions based upon U.S. foreign policy and national security goals, including export and re-export controls directed against targeted foreign countries, terrorism sponsoring organizations and international narcotics traffickers administered by the Office of Foreign Assets Control (“OFAC”) of the United States Department of the Treasury.

EAR

Export Administration Regulations (“EAR”) administered by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) for reasons of national security, foreign policy, antiterrorism, and non-proliferation applying to most commercial “dual-use” goods and technology, including, without limitation, the Commerce Control List, specifying controlled items and technology and the circumstances under which they may be exported, licensing requirements for certain exports, anti-boycott regulations, and the Entity List and the Denied Persons List which ban or limit exports to named persons or entities.

ITAR

International Traffic in Arms Regulations (“ITAR”), which regulate exports of defense articles and related technology and services that are identified on the U.S. Munitions List. It is administered by the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”).