ITAR Lawyer - Commodity Jurisdiction

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Stagg P.C. has a leading practice advising and representing clients before the U.S. Department of State on Commodity Jurisdiction (CJ) matters, including appeals and requests for reconsideration. The firm also advises and represents clients before the U.S. Department of Commerce on Commodity Classification (CCATS) requests. Stagg P.C. has handled a substantial number of large-scale classification projects, including those that involved over 50,000 items, and develops large-scale classification methodologies.

The firm's principal attorney was a former senior member of the commodity jurisdiction section at the U.S. Department of State's Directorate of Defense Trade Controls (DDTC) where he was involved in more than 500 CJ rulings, including requests for reconsideration and appeals. He was also a key member in re-writing the U.S. Munitions List, developing the "600 series" within the Commerce Control List for previously ITAR-controlled items, the new specially designed definition, authored the regulatory revisions to the CJ procedure, and developed DDTC's internal review process for CJ cases.

The firm has advised clients on determining whether to submit a CJ or CCATS request to the U.S. Government, developing the appropriate strategies for submitting the CJ or CCATS request, representing clients in CJ appeals to the Deputy Assistant Secretary of State for Defense Trade Controls or the Assistant Secretary of State for Political-Military Affairs, advocating the removal of items from the U.S. Munitions List, and handling a request for reconsideration of a previous CJ or CCATS.

The firm's jurisdiction and classification services include:

  • Assisting clients with self-determinations of items that are subject to the ITAR or the EAR, including developing jurisdiction/classification assessment systems and handling large-scale classification projects.
  • Handling Commodity Jurisdiction (CJ) and Commodity Classification (CCATS) requests to the U.S. Government, as well as Advisory Opinion requests to the Department of State for USML classifications.

  • Representing clients before the U.S. Department of State and the U.S. Department of Commerce in cases involving CJ or CCATS appeals and CJ or CCATS requests for reconsideration.

  • Providing legal opinion letters to clients on regulatory interpretations of the ITAR and EAR.

  • Formulating advisory opinion requests and responses to Federal Register Notices to the U.S. Government.

  • Resolving issues with third parties over jurisdiction and classification concerns.

  • Advocating the removal of items from the U.S. Munitions List pursuant to Section 38 of the Arms Export Control Act.

Our unique value. Stagg P.C. offers clients unique value into U.S. export controls laws. The firm's lawyers and advisors have former government experience at the Directorate of Defense Trade Controls within the U.S. Department of State. This experience involved administering and enforcing export control laws, as well as re-writing key aspects of the ITAR, EAR and control lists under the ongoing Export Control Reform initiative.

For more information, please contact Christopher Stagg at (212) 518-4854.

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