Clients praise Stephan Becker for his ‘excellent business acumen’ and ‘in-depth knowledge of U.S. import/export compliance law.’
Chambers USA 

Steve Becker leads Pillsbury’s International Trade practice. His work encompasses a broad range of legal subjects in the areas of international trade regulation and international law.

Steve advises clients on export control restrictions and embargoes; customs laws and duty-reduction programs; foreign investments in U.S. companies; and trade remedy proceedings such as antidumping and countervailing duty investigations. He works with companies from a range of industries, including semiconductors, aerospace, electronics, software, energy and agriculture. Steve represents companies, associations and foreign governments in administrative and criminal enforcement actions, international dispute settlement proceedings and domestic litigation involving international law.

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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. A member of Pillsbury's FCPA Task Force, Steve regularly counsels on compliance with the FCPA. 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.

Representative Experience

Represented a foreign government in dispute settlement proceedings at the WTO and in investor-state arbitrations.

Conducted a customs compliance audit for a client in the Importer Self-Assessment program.

Assisted clients with obtaining approvals for transactions in Cuba and other embargoed countries.

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  • 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 “off-shore” 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 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.
    • Advised solar components manufacturer on compliance with Buy American Act and Trade Agreements Act compliance issues.
    • 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.
    • Advised a manufacturer on customs law origin marking requirements and Trade Agreements Act domestic content rules.
    • 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.
    • Assisted a global manufacturer in evaluating the potential effect of free trade agreements on the relative costs of building a new factory in Asia.
    • 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.
    • Advised airline on customs enforcement matters involving submission of manifest data.
    • Advised airline on airline customs penalty actions.
  • 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 major international aerospace manufacturers with licenses to ship aircraft and components to sensitive countries and implementing compliance programs.
    • Advised major manufacturing companies with compliance and licensing issues in connection with proposed exports of products to Cuba.
    • Advised European manufacturers on the impact of the JCPOA on U.S. and EU sanctions on Iran.
  • Export & Technology Transfer Controls
    • Advised a major aerospace manufacturer on classification and licensing issues related to the incorporation of ITAR controlled content in civil aircraft.
    • Advised a non-U.S. company on Commerce Department license exceptions relating to aircraft, the overlap of U.S. sanctions and export control policies, and obtaining licenses authorizing exports to a jurisdiction subject to U.S. sanctions.
    • Designed and implemented export control internal compliance programs for domestic and multinational clients in the aviation, technology, satellite services and other industries.
    • Assisted global defense manufacturers in evaluating the application of the ITAR to technology exported under the U.S. Foreign Military Sales (FMS) program.
    • 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 the International Traffic in Arms Regulations (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 the ITAR.
    • Assisted a U.S. technology company in obtaining CFIUS clearance for its purchase by Spanish investors.
    • Advised nuclear engineering firm on possible FOCI mitigation agreements acceptable to the DOE to maintain or obtain facility clearance where the company was foreign owned and controlled.
  • 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 DOC, ITC, CIT, CAFC, and the first antidumping case at the U.S. Supreme Court.
    • Advised U.S. nuclear utilities in Uranium from Kazakhstan Suspension Agreement and Resumed Investigation involving novel issues related to the breakup of the Soviet Union and whether uranium stockpiles were Russian or Kazak origin.
    • Represented Government of Mexico in Administrative Review of Suspension Agreement in Sugar from Mexico.
    • Advised Mexican Government on settlement agreement in Cement from Mexico, 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.

Professional Highlights

Recognized by Chambers USA and Chambers Global in International Trade: Trade Remedies and Trade Policy, and by Chambers USA in International Trade: Export Controls & Economic Sanctions.

Presented “Shifting Landscape: Recent Developments in U.S. and EU Sanctions Rules” at The Compliance Forum, hosted by IMH, in Nicosia, Cyprus, Dec. 9, 2015.

Speaker, “Coherence, Conflict of Chaos in International Trade and Investment Dispute Settlement,” at the Canadian Council on International Law (CCIL) Annual Conference, Nov. 6, 2015.

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  • Honors & Awards
    • Best Lawyers in America, International Trade and Finance Law (2018)
    • Chambers USA, International Trade: Export Controls & Economic Sanctions Nationwide and International Trade: Trade Remedies & Trade Policy Nationwide (2017 – 2018)
    • Chambers Global, International Trade: Export Controls & Economic Sanctions Nationwide and International Trade: Trade Remedies & Trade Policy Nationwide (2017 – 2018)
    • The Legal 500 U.S., International Trade (2015-2017)
    • Legal 500 Latin America, Corporate M&A (2013)
    • Super Lawyers, International Trade (2013-2018)
    • Profiled as a key member of Pillsbury’s Latin Lawyer 250-ranked practice in the region.
  • Associations
    • American Bar Association
  • Speaking Engagements
    • “Talking Trump: the First 60 Days,” Gowling WLG conference, Calgary, Alberta, March 22, 2017
    • “OFAC Essentials: How US Sanctions Impact Companies in the GCC and what you Need to do to Protect your Company from Penalties,” C5’s 3rd annual forum on Trade Compliance in the Middle East, Dubai, UAE, March 7, 2017
    • “A Deep Dive Assessment of the Key Changes in Iran and Cuba Sanctions,” Practicing Law Institute, Coping with Export Controls Conference, Washington, DC, December 15, 2016
    • “Iran Sanction After Implementation Day,” The Export Practitioner, February 17, 2016
    •  Speaker, "What the Iran Nuclear Deal Will Mean for U.S. Business," The Export Practitioner, August 2015
    • “Unlock Your Guide to AML,” Protiviti Inc. webinar, December 11, 2014
    • “U.S. Sanctions Relating to the Unrest in Ukraine: Compliance Challenges,” Practicing Law Institute webinar, October 9, 2014
    • “Coping with US Export Controls,” Practicing Law Institute, Basics of Export Controls webinar, Washington, DC, November 11, 2013
    • “Recent Developments in Investment Arbitration,” presentation at the annual meeting of the Berne Union association of private and governmental export credit insurers, Jersey City, N.J., April 23, 2013
    • “Export Enforcement Issues,” U.S. Export Controls & Defense Trade Controls Seminar Series, hosted by Export Compliance Training Institute, Chicago, Ill., September 16, 2011
    • “Compliance Planning II – Is Your House Made of Straw, Sticks or Bricks? Manufacturing and Defense Industry Planning,” Coping with U.S. Export Controls 2010, hosted by Practicing Law Institute, Washington, DC, December 7, 2010
    • “The Intersection of E&C and Export Control Regulations,” Ethics & Compliance Officer Association’s 8th Annual Ethics and Compliance Conference, September 22, 2010
    • "Export Enforcement Issues,” U.S. Export Controls & Defense Trade Controls Seminar Series, hosted by Export Compliance Training Institute, Chicago, Ill., September 15, 2009
    • "The Extraterritorial Reach of US Sanctions: OFAC’s Application to Foreign Parties and Activities," Economic Sanctions Conference, hosted by American Conference Institute, February 2009
    • “Preventing Liability for Foreign Party Violations of U.S. Export/Reexport Controls,” Annual Forum on Export Controls, hosted by American Conference Institute, May 2009


  • J.D., Columbia University School of Law, 1982
    Law Review

    B.A., Yale University, 1979


  • District of Columbia


  • U.S. Supreme Court

    U.S. Court of Appeals for the Federal, District of Columbia, 7th and 9th Circuits

    U.S. Court of International Trade

    District of Columbia Court of Appeals