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Contact Information

Christopher B. Stagg
(212) 518-4854
[email protected]

Practice Areas

- Administrative Law
- Export Controls
- Economic Sanctions
- Federal Rulemaking
- Foreign Military Sales

Professional Memberships

- American Bar Association
- Export-Import Bar Association
- New York City Bar Association
- Society for International Affairs

Bar Admissions

- District of Columbia
- New York

Court Admissions

- U.S. District Court for the District of Columbia
 
- U.S. District Court for the Southern District of New York
 
- U.S. Court of Appeals for the Second Circuit

 

 
CHRISTOPHER B. STAGG

LATEST: Christopher Stagg will serve as the co-editor of the American Bar Association's Year-in-Review for Export Controls and Economic Sanctions. This is the sixth consecutive year that Mr. Stagg will serve as co-editor.

Recognized as a leading thought leader as well as lawyer of primary and last resort, Christopher Stagg offers unique experience and insight into export controls, economic sanctions, and federal rulemaking.

Mr. Stagg has previous government experience as one of the hands-on architects of the Export Control Reform initiative, which involved re-writing the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), the U.S. Munitions List, and Commerce Control List. Christopher was involved in revising every category of the U.S. Munitions List and developed U.S. policy for designating items as defense articles under the Arms Export Control Act.

With this background, Christopher understands export controls and national security issues from a regulator's perspective. He is frequently engaged as a lawyer of first resort to develop regulatory strategies and to analyze regulatory filings. He is also frequently engaged as a lawyer of last resort to reverse adverse government actions. For instance, Mr. Stagg has successfully advised defense primes and other companies with advisory opinion requests and commodity jurisdiction appeals to reverse an earlier government decision that would have adverse consequences.


Mr. Stagg's government experience also included deciding over 500 commodity jurisdiction requests and appeals, authoring advisory opinion responses that provided authoritative interpretative guidance under the ITAR, advising the Federal Bureau of Investigation, Department of Homeland Security and the Export Enforcement Coordination Center on high-profile export enforcement and other national security investigations, working with foreign governments on defense trade issues, and revising the government's policies and review procedures for commodity jurisdiction cases.

Mr. Stagg’s national security experience is further complemented by his experience at Jane’s Information Group, a leading defense information publisher and strategic advisory firm, in its consulting and editorial divisions. At Jane's Information Group, Christopher assessed defense industries, foreign militaries, and military weapon systems. He also reported on defense technologies for Jane's Defence Weekly.

Thought Leadership and Industry Involvement

Christopher is currently the Vice Chair of the Export Controls and Economic Sanctions Committee for the American Bar Association. As Vice Chair, he holds a leadership role and prepares the ABA's comments to proposed rulemaking involving the ITAR and EAR. Since 2013, Mr. Stagg has also been the co-editor of the ABA's Year-in-Review for Export Controls and Economic Sanctions.

Mr. Stagg has been featured on U.S. export control issues by publications such as Bloomberg, Forbes, Jane's Defence Weekly, WorldECR, and LexisNexis' Law360. He has presented on export controls at the Department of State, the American Bar Association, the Society for International Affairs, the New York City Bar Association, the Export Compliance Training Institute, the Embassy of Canada, and the Embassy of France.

Mr. Stagg is a recognized thought leader on export controls and writes extensively on critical topics, such as on complex statutory and constitutional issues. As an example of this leadership, Christopher recommended a significant revision to the ITAR in 2015 to define a key term that the Directorate of Defense Trade Controls accepted.

Previous Experience

Mr. Stagg was previously with a major international law firm in Washington, D.C. where he advised clients on export controls, economic sanctions, the Foreign Corrupt Practices Act (FCPA), international aviation law, foreign investment in the United States (CFIUS), and other national security issues. During law school, Christopher clerked for the U.S. Attorney's Office for the Southern District of Illinois.

Education

Mr. Stagg received his law degree from Saint Louis University School of Law and received his bachelor's degree from George Washington University. He also studied at the London School of Economics, the Yamasa Institute in Japan, and the Foreign Service Institute for classified coursework on intelligence and foreign policy.

Awards & Honors

> Export Control Reform, U.S. Department of State (2013)
> National Security Investigations, U.S. Department of State (2013)
> ICE Director's Award for Counterproliferation Investigations, U.S. Department of Homeland Security (2013)
> Export Enforcement, U.S. Department of Homeland Security (2013)
> Commodity Jurisdiction, U.S. Department of State (2011)

Representative Matters

> Assisted several U.S. defense primes with implementing an effective jurisdiction and classification system to handle the regulatory revisions for Export Control Reform, including the handling of items subject to the ITAR's see-thru rule policy.
> Successfully advised numerous companies in obtaining favorable regulatory interpretations through advisory opinion requests where the outcome would have a material business impact and may have resulted in a voluntary disclosure.
> Represented numerous companies in successful appeals and requests of reconsideration of Commodity Jurisdiction determinations, which resulted in moving the items from the U.S. Munitions List to the Commerce Control List.
> Assisted numerous clients in successful reconsiderations of Commodity Classifications (CCATS) with the Department of Commerce, which resulted in moving items to less restrictive controls.
> Advocated client positions in responses to proposed federal rules published in the Federal Register involving the ITAR and EAR to advance and protect the client's interests.
> Established export control compliance programs for numerous business entities that provide export controlled goods and services, including advanced encryption software subject to the ITAR and EAR.
> Assisted numerous U.S. defense companies on revising and updating existing corporate export compliance programs to handle the new regulatory requirements under Export Control Reform.
> Advised foreign companies on the applicability of the ITAR and EAR on products that incorporate U.S. origin goods and information to avoid potential export control violations.
> Advised U.S. defense information publisher on the ITAR's requirements for the use and dissemination of public domain information, including an assessment of the jurisdiction and classification of proposed new products.
> Carried out internal investigations of U.S. defense companies involving the potential violations of the ITAR and EAR, including counseling and preparation of voluntary disclosures.
> Advised numerous U.S. defense companies on the new brokering requirements and whether certain transactions constituted brokering activities under the ITAR.
> Prepared technical assistance agreements (TAA) and manufacturing licensing agreements (MLA) of a U.S. defense prime contractor to ensure compliance with the ITAR, the Agreements Guidelines, and revisions under Export Control Reform.
> Advised numerous U.S. aerospace and telecom companies on OFAC regulations concerning economic sanctions on Iran and Cuba, and opportunities for potential business development activities.

Speaking Engagements

> Presented at the Export Compliance Training Institute's ITAR Defense Trade Controls Seminar on November 12, 2018 in Alexandria, VA.
> Presented on "Export Control Reform Developments" at the American Bar Association's Year-in-Review Session in Washington, D.C. on February 28, 2018.
> Presented on "Export Control Reform Developments" at the American Bar Association's Year-in-Review Session in Washington, D.C. on February 7, 2017.
> Presented on "Export Controls: The Impact of ITAR Regulations to Your Industry & Your Business" at The Knowledge Group's webinar on January 11, 2017.
> Presented on "Export Control Reform and Compliance Strategies: Latest Developments in Export Controls" at The Knowledge Group's webinar on July 15, 2016.
> Presented on "The Art of the Voluntary Disclosure and Internal Investigation" for the Export Compliance Training Institute on May 4, 2016.
> Presented on "Significant Amendments to the International Traffic In Arms Regulations (ITAR)" at The Knowledge Group's webinar on March 1, 2016.
> Presented on "Export Control Laws: Practice and Procedure" at the New York City Bar Association in New York, NY on February 9, 2016.
> Presented on "Export Control Reform Developments" at the American Bar Association's Year-in-Review Session in Washington, D.C. on January 28, 2016.
> Presented on "Jurisdiction and Classification: Handling CJs, CCATS, and Self-Determinations" for the Export Compliance Training Institute on October 28, 2015.
> Presented on "ITAR and EAR Harmonization Rule - Preparing Comments" with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce, Edward Peartree of the U.S. Department of State and Jahna Hartwig of Sikorsky Aircraft Corporation for the American Bar Association (ABA) on July 21, 2015 in Washington, D.C.
> Presented on ""Responding to the State Department’s Proposed ITAR Prior Approval Requirement for Public Domain Information," in Washington, D.C. on July 8, 2015.
> Presented on "Export Controls: Administrative Law and Rulemaking," at the Impact of Export Controls on Higher Education & Scientific Institutions conference in Washington, D.C. on June 9, 2015.
> Presented with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce on "Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules," in Washington, D.C. on February 25, 2015.
> Presented on "ITAR to EAR: Mastering the Complexity and Maximizing the Benefits of the New Reform Rules" at The Knowledge Group's webinar on February 9, 2015.
> Presented on "Export Control Reform" and "ITAR Developments" at the American Bar Association's Year-in-Review Session in Washington, D.C. on January 22, 2015.
> Presented at NAITA's Export Control Roundtable on "Jurisdiction and Classification: State or Commerce? Has My Jurisdiction Changed as a Result of Export Control Reform?" in Huntsville, Alabama on December 4, 2014.
> Presented on "Export Control Reform" with Todd Willis of the U.S. Department of Commerce at SRA International's Managing the Legal & Regulatory Research Landscape Conference in Washington, D.C. on June 19, 2014.
> Presented on "Reclassifications of Controlled Goods: Incorporating US Export Control Reform, the Wassenaar Arrangement and EU Export Control Reforms into Your Approach" at C5's 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014.
> Presented on "US Export Control Reform Update: How to Prioritise your Compliance Approach to Operate under the EAR and Handle the Latest Reforms"at C5's 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014.
> Presented on “Export Controls and Space Research” at the Second Annual Impact of Export Controls on Higher Education and Scientific Institutions conference in Atlanta, GA on May 6, 2014.
> Presented on “Classification Post Export Control Reform” at the Society of International Affairs Conference on Export Control Reform in New Orleans, LA on May 5, 2014.
> Presented at the Embassy of Canada on "Export Control Reform: New Approaches and Opportunities for the Satellite Industry" in Washington, D.C. on March 12, 2014.
> Presented at the American Bar Association's CLE on export controls and economic sanctions in Washington, D.C. on January 22, 2014.
> Presented on "Advanced ITAR Issues: Practical Strategies For Managing Export Control Reform" in Washington, D.C., Dec. 17, 2013.
> Presented at the December meeting of the New York City Bar Association's International Trade Committee on "Export Controls, Economic Espionage, and National Security" in New York, NY, Dec. 3, 2013.
> Presented at the National Academies’ Government-University-Industry Research Roundtable in Washington, D.C. on “Understanding Research Globalization in the Context of National Security and Prosperity," Oct. 22, 2013
> Presented at the Embassy of France in Washington, D.C. on "Export Control Reform," Oct. 11, 2013.
> Presented at the Embassy of France in Washington, D.C. to "An Overview of U.S. Export Control Laws," Sept. 26, 2013.
> Presenter, “Addressing Classification and Jurisdictional Determinations,” ITAR Summit, Momentum Events, June 2013.
> Guest Lecturer, “The Lachmann Case and Specially Designed: Applications of Constitutional Law to Export Controls,” Georgetown University Law Center, June 2013.
> Presenter, “Update on Export Control Reform,” Private Conference, May 2013.
> Presenter, “Overview of the Commodity Jurisdiction Procedure,” U.S. Department of State In-House Training, March 2013.
> Presenter, “Export Control Reform: An Update and Primer,” ITAR Compliance Conference, Marcus Evans, Feb. 2013.
> Presenter, “Commodity Jurisdiction: Practical Tips and Considerations,” Private Conference, Sept. 2012.

Publications

> Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2018.
> Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2017.
> Authored "Next Steps for Export Control Reform: Options for the Trump Administration," Nov. 2016.
> Authored "DDTC Issues Conflicting Guidance Concerning Firearms and Congressional Notification," Nov. 2016.
> Authored, "Export Control Reform – Progress Made," WorldECR, May 2016.
> Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2016.
> Authored "The ITAR’s “Directly Related” Qualifier – The Importance of Defining the Term," Sept. 2, 2015.
> Authored "DDTC’s Arms Export Control Act Problem (In re: ITAR Proposed Rule on Prior Approval for Public Domain Information)," June 16, 2015.
> Authored "Toolkit for Writing Public Comments on Export Control Reform," May 4, 2015.
> Authored "DDTC Advances Proposed Rule for Cloud Computing, Defense Services, Technical Data, Public Domain, and Product of Fundamental Research," April 30, 2015.
> Authored "Status Update on Export Control Reform," April 22, 2015.
> Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2015.
> Authored "Court Case Reveals Insights into the Commodity Jurisdiction Procedure," March 16, 2015.
> Authored "DDTC Requests Public Comments on USML Categories VIII and XIX: Practical Tips for Preparing Effective Comments," March 2, 2015.
> Authored "The Curious Case of Technical Data as a Defense Article - And Potential Consequences for Cloud Computing," Feb. 19, 2015.
> Authored "The Strategic Commodity Jurisdiction (CJ) Request," Feb. 16, 2015.
> Authored "DDTC Issues Overly Expansive Interpretation of the ITAR for Defense Services (and Presumably Technical Data)," Dec. 8, 2014.
> Authored "Influencing Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules," Dec. 1, 2014.
> Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2014.
> Authored "Export Control Reform: A Review And Look Ahead" for LexisNexis Law360, Dec. 19, 2013.
> Quoted for Export Control Reform by Bloomberg BNA in "Final Rules Now Effective Revising Controls For Items Related to Aircraft, Turbine Engines," Oct. 15, 2013.
 
 
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