Stephan E. Becker

Steve has represented clients in numerous international dispute settlement proceedings conducted under the rules of regional trade agreements, the World Trade Organization and the International Centre for the Settlement of Investment Disputes. He represents U.S. and non-U.S. companies in preparing submissions to CFIUS and complying with the other legal obligations that can arise when foreign interests invest in the U.S. He also assists clients with obtaining license approvals, preparing voluntary disclosures of violations, establishing internal corporate compliance programs and determining whether proposed transactions are permissible.

• Anti-Money Laundering
  • Provided advice to Middle Eastern free trade zone regarding improvement of their AML and sanctions compliance programs, including a review of best practices among “offshore” and entity-forming jurisdictions in the wake of the Panama Papers revelations.
  • Provided advice to multiple banks in Cyprus regarding improving their AML and sanctions compliance programs.
• Customs Compliance & Enforcement
  • Advised aviation industry stakeholders, including global OEMs, MROs and an international trade group, on tariff and customs developments, Section 232 aircraft investigations, and the impact of U.S. and EU trade policies on financing and commercial strategies.
  • Advised on the scope of U.S. requirements for use of domestic vessels in “coastwise trade” of oil under the Jones Act.
  • Advised petroleum company on compliance issues concerning operations within U.S. foreign trade zones.
  • Successfully appealed to CBP Headquarters a change in tariff classification made at a port, resulting in the cancellation of CBP invoices for $20 million in duties.
  • Assisted the U.S. subsidiary of a major foreign manufacturer with a Focused Assessment audit by CBP, including being present for the entire audit.
  • Represented a U.S. company in negotiating a settlement with CBP of an enforcement action involving a failure to add the value of “assists” to the value of imported goods.
  • Assisted manufacturing company enrolled in the Importer Self-Assessment program with its annual internal audits.
  • Represented a producer of food products in an administrative enforcement action in which CBP alleged that the imports did not comply with the NAFTA rules of origin.
  • Represented a manufacturer in obtaining CBP ruling that a remanufactured product could be considered substantially transformed in the U.S. and therefore eligible for sale to federal agencies.
  • Advised commercial manufacturer on regulatory issues arising from inadvertent importation of radioactive products.
  • Assisted U.S. semiconductor company in enrolling in the Importer Self-Assessment program, including the site visit by CBP; also assisted client with a full-day C-TPAT verification audit.
• Economic Sanctions and Embargoes
  • Provided advice to foreign banks regarding improving their AML and sanctions compliance programs.
  • Assisted financial institutions, real estate companies and other businesses on the negotiation of contract language addressing compliance with Executive Orders and sanctions regulations.
  • Assisted international aerospace manufacturers with obtaining licenses to ship aircraft and components to sensitive countries and implementing compliance programs.
• Export & Technology Transfer Controls
  • Advised a European missile systems manufacturer on ITAR and EAR compliance, including derivative data, complex licensing arrangements and compliance program administration across multiple jurisdictions.
  • Advised a global military communications equipment manufacturer on export control compliance, including ITAR licensing agreements, deemed export issues, and U.S. person abroad requirements across multiple jurisdictions.
  • Advised global aircraft parts suppliers and MRO service providers on ITAR and EAR compliance, sanctions, licensing, and defense service authorizations, including matters involving civil, military and embargoed-country aircraft.
  • Advised a major aerospace manufacturer on classification and licensing issues related to the incorporation of ITAR-controlled content in civil aircraft.
  • Designed and implemented export control internal compliance programs for domestic and multinational clients in the aviation, technology, satellite services and other industries.
  • Provided support in multiple locations to internal audit and assurance exercises focused on export control and technology transfer controls for a global defense company.
  • Performed due diligence on export control compliance in connection with private equity acquisitions.
  • Advised electronics and semiconductor companies on compliance with encryption regulations under the EAR, and related filings including registration, classification and reporting.
• Regulation of Foreign Investment & National Security
  • Represented Japanese multinational corporation in acquiring large U.S. entity involved in activities regulated under ITAR. Assisted in the negotiation of a mitigation agreement with CFIUS and in satisfying requirements imposed by the Directorate of Defense Trade Controls in connection with the pre-notification requirements of ITAR.
  • Assisted a U.S. technology company in obtaining CFIUS clearance for its purchase by Spanish investors.
  • Advised nuclear engineering firm on FOCI mitigation agreements to maintain or obtain facility clearance where the company was foreign owned and controlled.
• International Dispute Settlement
  • Participated as counsel in the following WTO disputes:
    1. United States – Measure Concerning the Importation, Marketing, and Sale of Tuna and Tuna Products
    2. United States – Certain Country of Origin Labelling (COOL) Requirements
    3. Mexico – Tax measures On Soft Drinks And Other Beverages
    4. Mexico – Measures Affecting Telecommunications Services
    5. Mexico – Antidumping Investigation of High Fructose Corn Syrup (HFCS) from the United States
  • Participated as counsel in government-to-government dispute settlement proceedings under the NAFTA (In The Matter Of The U.S. Safeguard Action Taken On Broom Corn Brooms From Mexico, and In the Matter of Cross-Border Trucking Services and Investment) and U.S.-Israel Free Trade Agreement (In the Matter of Machine Tools from Israel).
  • Participated as counsel in over 35 pending and completed investment arbitrations arising under trade and bilateral investment treaties.
• Trade Remedy Proceedings
  • Organized and represented nuclear industry coalition, known as the Ad Hoc Utilities Group (AHUG), with unique standing in novel trade remedy dispute involving whether sales of services could be subject to the antidumping laws before the Commerce Department, the International Trade Commission, and the first antidumping case to reach the U.S. Supreme Court.
  • Represent Government of New Brunswick in countervailing duty investigation and administrative reviews in Softwood Lumber from Canada case, including before the Commerce Department, the courts, and USMCA binational panels.
  • Represented Government of Mexico in administrative review of Suspension Agreement in sugar from Mexico.
  • Advised Mexican government on settlement agreement involving Mexican cement, resolving a complex trade dispute that lasted many years and involved administrative litigation, judicial appeals and WTO disputes.
  • Obtained first-ever new shipper review in antifriction bearings from Germany, Italy, Sweden and Japan.
  • Represented tire producer in antidumping proceeding involving tires from China.

• Honors & Awards
  • Chambers USA, International Trade: Export Controls & Economic Sanctions Nationwide (2015 – 2025) and International Trade: Trade Remedies & Trade Policy Nationwide (2008 – 2025)
  • Recommended for Trade & Customs by Lexology Index (2025)
  • Recommended by Who’s Who Legal as a Global Leader in Trade & Customs (2022)
  • Acritas Star, Acritas annual General Counsel Survey (2021)
  • Super Lawyers, International Trade (2013 – 2020, 2022 – 2023)
  • Profiled as a key member of Pillsbury’s Latin Lawyer 250-ranked practice in the region.
• Speaking Engagements
  
  • “Regulatory Update: Adapting to Supply Chain Changes in a Heightened National Security Environment,” GovCon East 2025, January 16, 2025.
  • “The Next Phase Russia Sanctions and Export Controls Compliance: Positioning Your Program, People and Training to Tackle the Knowns (and Unknowns) of What’s Ahead,” ACI’s Forum on Advanced Global Export Controls, Washington, D.C., February 29, 2024.
  • “Emerging Issues in Supply Chain Management: Buy America, Section 889, Proposed Climate Initiatives, and Employment Non-Competes,” Pillsbury’s 2023 East Coast Government Contracts Summit, Northern Virginia, May 16, 2023.
  • “Buy American and Sanctions Developments: New Risks for Contractors,” Public Contracting Institute's Supply Chain Symposium, April 18, 2023.
  • “Grappling with the Uyghur Forced Labor Prevention Act,” USCIB, February 1, 2022.
• External Publications
  • “Investment Treaty Arbitration: USA,” Global Arbitration Review, 9/2024. Co-author.