Representative Experience

Represented the U.S. subsidiary of a foreign manufacturing company raided by FBI and OEE agents, conducting an internal investigation, and negotiating with the U.S. Attorney’s office, which ultimately declined to prosecute, and OEE, which issued a warning letter.


Designed and implemented export control internal compliance programs for domestic and multinational clients in the aviation, technology, satellite services and other industries.


Took over day-to-day responsibility for all export control compliance functions associated with U.S. sourcing of a Swedish aerospace and defense firm when it unexpectedly lost its internal compliance personnel.

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  • Aerospace
    • Advised a major aerospace manufacturer on classification and licensing issues related to the incorporation of ITAR controlled content in civil aircraft.
    • Took over day-to-day responsibility for all export control compliance functions associated with US sourcing of a Swedish aerospace and defense firm when it unexpectedly lost its internal compliance personnel.
    • 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.
    • Prepared Commodity Jurisdiction request to determine the ITAR or EAR control of sophisticated adaptive optics equipment for aerospace communications project.
    • Conducted an internal investigation for a major aerospace manufacturer of ITAR Part 130 reporting of fees and commissions, analyzed Part 129 broker registration and licensing requirements, and reporting to DDTC.
    • Drafted export compliance policy to assist US and Canadian aerospace company with trade and security compliance, including preparing and submitting a Technical Assistance Agreement (TAA) related to its foreign affiliate company.
    • Counseled aerospace software client regarding both US government and self-classifications of aircraft and spacecraft-related software products, involving a CJ reconsideration in light of export control reform, as well as engagement with government officials during dispute resolution procedures when CJ reviewing agencies disagreed.
    • Advised defense and commercial companies on cybersecurity attacks and guiding them on voluntary disclosures resulting from potential export control violations.
    • Structured and prepared Technical Assistance, Manufacturing License and Distribution Agreements as well as export and temporary import licenses submitted to DDTC for U.S. and foreign defense manufacturers, aerospace and software companies.
    • Advised European small satellite manufacturer with voluntary self-disclosure, services and support authorization, and de minimis calculation regarding satellite component.
    • Designed and implemented export control internal compliance programs for domestic and multinational clients in the aviation, technology, satellite services and other industries.
    • Assisted European aircraft ground system manufacturer in obtaining CCATS determination for its product.
    • Prepared industry comments on behalf of satellite client in connection with export control reform, contributing substantially to revised rules on spacecraft.
    • Advised satellite company reorganization-related registration and license filings before the Department of State.
    • Advised satellite company on compliance with ITAR and EAR rules including transition to EAR due to Export Control Reform.
    • Advised on TAA and strategic export planning and registration for satellite services company relating to plans in Europe and Australia, including preparation of an export compliance plan.
    • Served as an expert witness in UK litigation concerning the financial interests of various parties in US manufactured aircraft illegally leased to Iran, addressing EAR and ITAR prohibitions on aircraft exports to Iran and License Exception AVS.
    • Drafted Know Your Customer Compliance Manual for an aircraft leasing and financing company.
    • Advised aviation technology company on export control classification and technology transfer issues in connection with the company's development activities.
  • Defense
    • Supported preparation and filing of bulk license for items on military aircraft platform subject to the EAR following export control reform changes.
    • Conducted extensive internal investigation related to alleged ITAR and EAR criminal and civil violations for a private security contractor and preparing comprehensive voluntary disclosures to DDTC, BIS and Census regarding exports of controlled items and provision of potential defense services.
    • 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.
    • Provided training sessions and internal assessments for global defense manufacturer on control of technology, technical data and derived data in the wake of U.S. export control reform.
    • Prepared comments for regulatory changes by DDTC and BIS under export control reform and other regulatory updates.
    • Assisted clients in assessing export control requirements applicable to intelligence and surveillance products and technologies.
    • Advised global defense and intelligence technology services provider on DSS and ITAR compliance in connection with acquisition of US software engineering firm.
    • Advised brokers of U.S. defense articles on revisions to licensing and registration requirements relating to activity in the Middle East.
    • Prepared M&A trade due diligence questionnaire for US-headquartered security services provider.
  • Financial
    • Performed due diligence on export control compliance in connection with private equity acquisitions.
    • Assisted a major global financial institution and media company on the classification of a wide range of proprietary software applications, including the application of EAR controls on cryptographic functionality.
  • Manufacturing
    • Represented the US subsidiary of a foreign manufacturing company raided by FBI and OEE agents, conducting an internal investigation, and negotiating with the US Attorney’s office, which ultimately declined to prosecute, and OEE, which issued a warning letter.
    • Advised marine manufacturer on export control matters including obtaining CJs and CCATS, and reviewing EAR and ITAR licenses in connection with its customers.
    • Worked with a major electronics manufacturer to navigate the overlap of U.S. export controls and evolving sanctions policies for Iran which permit certain sales of consumer electronics and services to enable internet access and communication.
    • Conducted an internal investigation of a major international oil field services company resulting in BIS voluntary disclosure and advised on logistics processing and supply chain management issues.
    • Advised multinational petroleum company on encryption import requirements of non-U.S. jurisdictions including China, Singapore, Russia and South Korea and obtaining import licenses where necessary.
  • Technology, Software and Outsourcing
    • Assisted social media and technology company on directed Homeland Security disclosure, DDTC voluntary self-disclosure, and ITAR and EAR compliance issues.
    • Conducted internal investigation and designed a strategy of complementary licensing, CCATS and voluntary disclosure filings to address the export of encryption software and potential prior violations.
    • Utilized administrative procedures to appeal denial of license filing with BIS and the Department of Commerce.
    • Advised social media and technology company on export control laws in connection with global satellite and UAV communications project.
    • Obtained EAR99 CCATS ruling under recently revised encryption rules for network management software with encryption call functionality based on decontrol for Operations, Administration or Maintenance.
    • Performed due diligence on export control matters in connection with acquisition of video streaming company.
    • Advised Asian chip manufacturer with product having U.S. content on U.S. reexport rules as well as encryption and Wassenaar export rules for Asian markets -- Malaysia, Singapore, Korea, etc.
    • Conducted internal investigation on printer manufacturer and its subsidiaries concerning Iran and Syria transactions, and prepared disclosures to OFAC and BIS.
    • Helped lead effort by a social media and technology company on a companywide update of export control and technology control plans.
    • Advised software developer regarding encryption controls, prepared BIS voluntary disclosure and obtained services and support authorization in advance of potential acquisition.
    • Prepared M&A procedures and questionnaires for a social media and technology company to address trade compliance issues for targets.
    • Reviewed and analyzed export control issues in connection with acquisition of semiconductor company.
    • Advised on and drafted export control provisions in master services agreements for outsourcing applications development and maintenance functions to offshore entities.
    • Advised electronics and semiconductor companies on compliance with encryption regulations under the EAR, and related filings including registration, classification and reporting.
  • Life Sciences and Research
    • Advised major national research universities on ITAR registration issues and the scope and application of the fundamental research exclusion to space-related research projects.
    • Conducted a comprehensive review of life science company's export control compliance matters, including drafting policies and procedures, enhancing the company's export classification database, and submitting a voluntary self-disclosure.
    • Reviewed and analyzed export control issues in connection with potential acquisition of U.S.-based medical optics company by a publicly traded Japanese corporation.
    • Advised consultant Management Company on export control compliance of potential target companies.

Practice Area Highlights

Pillsbury’s International Trade practice is nationally ranked by Chambers USA.


Team partners Stephan Becker, Nancy Fischer and Christopher Wall ranked as Chambers USA and Chambers Global leading lawyers in International Trade, and we are recognized for Export Controls & Economic Sanctions work.


Pillsbury received U.S. News/Best Lawyers recognition for International Trade & Finance and International Trade lawyer and practice recognition from The Legal 500 U.S.