ITAR Lawyer - Commodity Jurisdiction

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Representative matters

> Assisted several U.S. defense primes with implementing an effective export control jurisdiction and classification system, including the handling of technical data, defense services, brokering activities and items subject to the ITAR's see-thru rule policy.
> 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 (CJ) 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.
> Conducted internal investigations for numerous companies to review whether a potential violation has taken place and to take appropriate steps to implement corrective actions and government disclosures.
> 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 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.

For more information, please contact Christopher B. Stagg at (212) 518-4854 or by e-mail at

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