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Vital Advice on International Trade Matters
Josephine provides valuable advice on compliance and enforcement of U.S. export control regulations and economic sanctions, bringing a practical and detail-focused analysis to "bet-the-company" international transactions and enforcement matters, novel business prospects, and ongoing compliance-related issues.
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Recognized by Clients and Peers as a Top International Trade Attorney
Josephine has been ranked among the top international trade (Export Controls and Trade Sanctions) attorneys in the U.S. since 2010 in Chambers USA and a top practitioner in this area worldwide since 2012 as rated in Chambers Global.
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An Authority and Thought Leader on International Trade Topics
Josephine often speaks on export control and trade sanctions topics and has chaired conferences focused on international technology transfers.
Josephine Aiello LeBeau is a partner in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, counseling domestic and foreign companies on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions.
Josephine counsels clients on potential export control liabilities stemming from cross-border technology transfers, joint venture projects, mergers and acquisitions, foreign investment, foreign distributor agreements, and virtual delivery of products and services. She works closely with companies in designing and implementing internal compliance programs, conducting internal investigations and compliance assessments, training employees on regulatory compliance issues, preparing voluntary disclosures, and settling enforcement actions with U.S. government agencies.
Josephine’s practice is at the forefront in assisting clients with new regulatory challenges, including navigating the analysis of Huawei/ZTE transactions in light of changing regulations, classification of “critical technologies” as they may apply to CFIUS analyses, obtaining licenses from the Office of Foreign Assets Controls related to Russian entities that have been sanctioned, and obtaining hundreds of “deemed export” licenses for clients that employ H-1B visa holders in export-controlled areas. She is an expert in commercial and dual-use controls promulgated under the Export Administration Regulations, military-specific controls administered under the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control.
Recognized as a top international trade attorney in various editions of Chambers USA, sources report that Josephine “displays strong legal analysis combined with a firm grasp of business practicality to make her advice particularly useful” and “is one of the top attorneys in the U.S. on EAR and OFAC issues for the technology industry." Clients also note Josephine “consistently provides excellent advice” and her “insight and responsiveness are a great asset and comfort.” She has also been named among the country's top international trade attorneys in Chambers Global since 2012 and selected for inclusion in various publications including Washington DC Super Lawyers and the Women in Business Law Expert Guide.
Josephine frequently speaks on export control and trade sanctions issues and has chaired several conferences focusing on international technology transfers.
Josephine Aiello LeBeau is a partner in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, counseling domestic and foreign companies on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions.
Josephine counsels clients on potential export control liabilities stemming from cross-border technology transfers, joint venture projects, mergers and acquisitions, foreign investment, foreign distributor agreements, and virtual delivery of products and services. She works closely with companies in designing and implementing internal compliance programs, conducting internal investigations and compliance assessments, training employees on regulatory compliance issues, preparing voluntary disclosures, and settling enforcement actions with U.S. government agencies.
Josephine’s practice is at the forefront in assisting clients with new regulatory challenges, including navigating the analysis of Huawei/ZTE transactions in light of changing regulations, classification of “critical technologies” as they may apply to CFIUS analyses, obtaining licenses from the Office of Foreign Assets Controls related to Russian entities that have been sanctioned, and obtaining hundreds of “deemed export” licenses for clients that employ H-1B visa holders in export-controlled areas. She is an expert in commercial and dual-use controls promulgated under the Export Administration Regulations, military-specific controls administered under the International Traffic in Arms Regulations, and economic sanctions programs implemented by the Office of Foreign Assets Control.
Recognized as a top international trade attorney in various editions of Chambers USA, sources report that Josephine “displays strong legal analysis combined with a firm grasp of business practicality to make her advice particularly useful” and “is one of the top attorneys in the U.S. on EAR and OFAC issues for the technology industry." Clients also note Josephine “consistently provides excellent advice” and her “insight and responsiveness are a great asset and comfort.” She has also been named among the country's top international trade attorneys in Chambers Global since 2012 and selected for inclusion in various publications including Washington DC Super Lawyers and the Women in Business Law Expert Guide.
Josephine frequently speaks on export control and trade sanctions issues and has chaired several conferences focusing on international technology transfers.
- J.D., Harvard Law School, 1995Articles Editor, Harvard Journal of Law & Technology; Technical Editor, Harvard Journal on Legislation
- B.A., Political Science, and B.S., Computer Science, Tulane University, 1992Summa Cum Laude, Phi Beta Kappa
- Named among the country's top international trade attorneys in the 2010-2023 editions of Chambers USA: America's Leading Lawyers for Business
- Recognized in the International Trade: Export Controls & Economic Sanctions category of the 2012-2024 editions of Chambers Global: The World's Leading Lawyers for Business
- Selected for inclusion in the 2017-2021 editions of Washington DC Super Lawyers
- Recognized as the "Best in Export Control Regulation - USA" in the 2016 Legal Awards by Acquisition International
- Selected for inclusion in the 2013 Women in Business Law Expert Guide
- Honored as a "BTI Client Service All-Star" for 2013
- Bar of the District of Columbia
- State Bar of Virginia
- J.D., Harvard Law School, 1995Articles Editor, Harvard Journal of Law & Technology; Technical Editor, Harvard Journal on Legislation
- B.A., Political Science, and B.S., Computer Science, Tulane University, 1992Summa Cum Laude, Phi Beta Kappa
- Named among the country's top international trade attorneys in the 2010-2023 editions of Chambers USA: America's Leading Lawyers for Business
- Recognized in the International Trade: Export Controls & Economic Sanctions category of the 2012-2024 editions of Chambers Global: The World's Leading Lawyers for Business
- Selected for inclusion in the 2017-2021 editions of Washington DC Super Lawyers
- Recognized as the "Best in Export Control Regulation - USA" in the 2016 Legal Awards by Acquisition International
- Selected for inclusion in the 2013 Women in Business Law Expert Guide
- Honored as a "BTI Client Service All-Star" for 2013
- Bar of the District of Columbia
- State Bar of Virginia
Select Publications
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Co-author, “BIS Expands Export Controls on Advanced Computing Integrated Circuits for Supercomputer and Semiconductor End Use, and on Semiconductor Manufacturing Equipment and Related Equipment to China,” Wilson Sonsini Alert, October 20, 2023
- Co-author with J. Cheng, J. Davey, J. Hartwig, S. Heifetz, T. Jenkins, and A. Seymour, “OFAC Penalizes Another Crypto Asset Company for Sanctions Violations,” Wilson Sonsini Alert, May 22, 2023
- Co-author with K. Millard and S. Patak, “United States Imposes Export Restrictions on Beijing Genomics Institute (BGI) Group Subsidiaries over National Security Concerns,” Wilson Sonsini Alert, March 21, 2023
- Co-author with J. Hartwig and K. Millard, “'Disruptive Technology Strike Force' to Target Protection of Sensitive Technologies, Export Controls Circumvention,” Wilson Sonsini Alert, February 27, 2023
- Co-author with B. Poellot and A. Seymour, “BIS Announces New End-Use Check Policy; Adds YMTC, 30 Additional Chinese Entities to Unverified List,” Wilson Sonsini Alert, October 14, 2022
- Co-author with B. Poellot and A. Seymour, "BIS Implements New Semiconductor- and Supercomputer-related Export Controls and End-Use Controls," Wilson Sonsini Alert, October 13, 2022
- Co-author with K. Millard and A. Seymour, "New Russia Sanctions Imposed as Ukraine War Continues: Expansion of Controls on EAR99 Items and Military End-Uses," Wilson Sonsini Alert, September 19, 2022
- Co-author with K. Millard and A. Seymour, "Russia Sanctions Update: Intellectual Property General License and a Prohibition on the Provision of Some Services," Wilson Sonsini Alert, May 11, 2022
- Co-author with K. Millard and A. Seymour, "New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates," Wilson Sonsini Alert, April 11, 2022
- Co-author with K. McDonough and A. Seymour, "License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls, OFAC Clarifies Earlier Restrictions in Russia-Ukraine Crisis," Wilson Sonsini Alert, March 3, 2022
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Co-author with M. Casey, J. Hartwig, K. McDonough, and A. Seymour, "Biden Administration Implements Significant BIS Controls and Imposes Second Tranche of OFAC Sanctions in Russia-Ukraine Crisis," Wilson Sonsini Alert, February 25, 2022
- Co-author with J. Hartwig, K. McDonough, and A. Seymour, "Biden Administration Authorizes New Sanctions on Regions of Ukraine," Wilson Sonsini Alert, February 23, 2022
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Co-author with A. Seymour, "Intrusion Preclusion: BIS Issues Long-Awaited Controls on Cybersecurity Items, Creates New License Exception," Privacy & Cybersecurity Law Report, February-March, 2022
- Co-author with J. Hartwig and A. Seymour, "U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations," Wilson Sonsini Alert, February 4, 2022
- Co-author with M. Casey, J. Hartwig, S. Heifetz, and A. Seymour, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
- Co-author with M. Casey, K. McDonough, and A. Seymour, "2021 U.S. Sanctions Year in Review," Wilson Sonsini Alert, January 13, 2022
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Co-author with J. Hartwig, K. McDonough, and A. Seymour, "Know Your Customer: OFAC, BIS Penalize Companies for Sales of 'EAR99' Items and Services to Prohibited Parties Through Distributors," Wilson Sonsini Alert, September 21, 2021
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Co-author with J. Hartwig, K. McDonough, and A. Seymour, “Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports,” Wilson Sonsini Alert, August 19, 2021
- Co-author with A. Seymour, “President Biden Issues Executive Order Amending Restrictions on Chinese Military and Surveillance Companies,” Wilson Sonsini Alert, June 11, 2021
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Co-author with M. Mannino and A. Seymour, “Take Two: Another Executive Order Addresses U.S. Personal Data Concerns by Prohibiting Business with Companies that Develop or Control Eight Specified Applications with Connections to China,” Wilson Sonsini Alert, January 6, 2021
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Co-author with M. Mannino and A. Seymour, “U.S. Government Authorization Now Required for Certain Business with SMIC and Over 70 Additional Entities in China," Wilson Sonsini Alert, December 19, 2020
- Co-author with J. Gruenspecht, S. Heifetz, M. Mannino and A. Seymour, “As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat,” Wilson Sonsini Alert, September 21, 2020
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Co-author with J. Gruenspecht, M. Mannino, and A. Seymour, “U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That are Prohibited Due to National Security Concerns Raised by TikTok and WeChat,” Wilson Sonsini Alert, September 18, 2020
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Co-author with J. Davey, M. Mannino, and A. Seymour, “Expansion of U.S. Export Controls on Huawei-Designed or Produced Items,” Wilson Sonsini Alert, May 29, 2020
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Co-author with J. Davey, M. Mannino, and A. Seymour, “License Requirements and U.S. Government Visibility into Exports to China, Russia, and Venezuela Will Increase, but Countries Remain Open for U.S Business,” Wilson Sonsini Alert, May 1, 2020
- Co-author with M. Mannino and A. Seymour, “Artificial Intelligence Software Controlled for Export, Including to Foreign National Employees,” Wilson Sonsini Alert, January 10, 2020
- Co-author with M. Mannino and A. Seymour, “License to Be Required for Exports, Reexports, and Transfers of U.S.-Origin Items to 28 Additional Chinese Entities,” WSGR Alert, October 8, 2019
- Co-author with M. Mannino and A. Seymour, “Export Control Update: 46 Huawei Affiliates Added; License Extended,” WSGR Alert, August 21, 2019
- Co-author with M. Mannino and A. Seymour, “License Required for Exports and Other Items Sent to Huawei and Affiliates,” WSGR Alert, May 17, 2019
- Co-author with J. Gruenspecht, S. Heifetz, M. Mannino, and A. Seymour, “Emerging Technologies to Be Controlled for Export: Comments Due December 19, 2018,” WSGR Alert, November 19, 2018
- Co-author with M. Mannino and A. Seymour, “ZTE Update: Denial of Export Privileges Suspended,” WSGR Alert, July 17, 2018
- Co-author with A. Seymour, “ZTE Update: Order Signed, but Denial of Export Privileges Still is in Effect,” WSGR Alert, June 11, 2018
- Co-author with M. Mannino and A. Seymour, “Denial of Export Privileges Against ZTE Corporation to be Lifted Once Order is Signed,” WSGR Alert, June 6, 2018
- Co-author with M. Mannino, “Reminder: Mandatory Foreign Direct Investment Reports for U.S. Entities Due May 31,2018,” WSGR Alert, May 8, 2018<
- Co-author with M. Mannino and A. Seymour, “ZTE Corporation Sanctioned Again – Prohibitions on Transactions Involving U.S.-Origin Items Effective Immediately,” WSGR Alert, April 18, 2018
- Co-author with D. Glazer, M. Mannino, A. Seymour, and J. Lynch, "Forms Issued for U.S. Mandatory Foreign Direct Investment Reporting," WSGR Alert, March 9, 2018
- Co-author with M. Mannino, D. Glazer and J. Lynch, “Mandatory Reporting for Entities in 2018 Regarding Foreign Direct Investment”, WSGR Alert, Dec 4, 2017
- Co-author with M. Labriola, M. Mannino, and A. Seymour, "OFAC Due Diligence in Securities Offerings," Lexis Practice Advisor, November 16, 2017
- Co-author, "Continuation of ZTE General License Until February 27, 2017," WSGR Alert, November 21, 2016
- Co-author, "U.S. Further Eases Embargo on Cuba," WSGR Alert, October 17, 2016
- Co-author, "BIS Modifies Rules Governing the Export of Information Security Items Under the Export Administration Regulations; Updates to Cuba Regulations Coming Next Week," WSGR Alert, October 14, 2016
- Co-author, "Second Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, August 18, 2016
- Co-author, "Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, June 28, 2016
- Co-author, "Department of Commerce to Ease License Requirement for Exports, Reexports, and Transfers to ZTE as of March 24, 2016," WSGR Alert, March 22, 2016
- Co-author, "License Required for All Exports, Reexports, and Transfers to ZTE Corporation as of March 8, 2016," WSGR Alert, March 7, 2016
- Co-author, "Iran Not Open for U.S. Business: U.S. Trade Embargo Remains in Place; Nuclear Sanctions Lifted," WSGR Alert, January 19, 2016
- Co-author, "Proposed Rule to Subject Certain Cybersecurity Items to Greater Export Restrictions," WSGR Alert, July 9, 2015
- Co-author, "U.S. Companies with Foreign Subsidiary or Affiliate Granted One-Month Extension to File Mandatory Forms," WSGR Alert, June 1, 2015
- Co-author, "Restrictions Eased for Communications-Related Items Exported to Sudan," WSGR Alert, March 24, 2015
- Co-author, "Reporting Requirements for U.S. Companies Regarding Direct Investment," WSGR Alert, March 18, 2015
- Co-author, "U.S. Relaxes the Half-Century-Old Embargo on Cuba," WSGR Alert, January 16, 2015
- Co-author, "Increasing Russian Sanctions Target Financial and Energy Sectors," WSGR Alert, July 21, 2014
- Co-author, "More Restrictions on Business with Russia," WSGR Alert, May 1, 2014
- Co-author, "U.S. Expands Sanctions on Russia in Light of Crisis in Ukraine," WSGR Alert, March 26, 2014
- Co-author with Joshua Holzer, "2008 Olympics in China Pose Legal Risks for U.S. Exporters," The Export Practitioner, Vol. 21, No. 5, May 2007
- "Cloud Computing from A to Z: How to Safely Store Export Controlled Data," 11th Annual Advanced Export Controls Forum on International Technology Transfers, Washington, D.C., February 5, 2019
- "Life Sciences & Export Compliance: Avoid the Pitfalls and Take Advantage of Unique Exemptions and Policies," WSGR event, Boston, July 19, 2018
- "Avoiding Sanctions Risks: How to Navigate OFAC Rules for Web Based Interactions, Cloud Computing, and Shared Networks," ACI's 10th Annual Advanced Forum on Economic Sanctions Enforcement and Compliance, Washington, D.C., April 24, 2017
- "'Technical Data' and the 'Specially Designed' Rule: Group Exercises on How to Apply These Complicated Definitions to Challenging, Real-Life Dilemmas," ACI's Ninth National Export Controls Forum on International Technology Transfers, Cloud Computing and Deemed Exports, Washington, D.C., October 18, 2016
- "Wassenaar: How New Proposals, 2015 Controls, and Countries' Adoption of Note 4 and OAM Affect Your Global Encryption Compliance Strategy," ACI Global Encryption, Cloud & Cybersecurity Controls Conference, San Francisco, March 30, 2016
- Panelist, "Understanding Disclosure: Best Practice," IBC Global Trade Controls & Compliance Conference, London, November 20, 2015
- "Intangible Exports, Cloud Computing, and Export Controls," IBC Global Trade Controls and Compliance Conference, London, November 19, 2014
- Roundtable Speaker with Olga King, "Lessons Learned from the Esterline, Intevac and Meggitt Cases: How to Manage a Government Investigation, Mitigate Exposure and Restore Confidence," Eighth National Export Controls Forum on International Technology Transfers and Deemed Export Compliance, San Francisco, California, September 16, 2014
- "Understanding the Problems of Intangible Exports Including 'Cloud Computing' and Data Transfer," Global Trade Controls and Compliance 26th Annual Conference, London, November 2013
- "Commodity Jurisdiction Determinations: Proven Strategies for Drafting an Effective Request and How to Interpret a DDTC Determination," The ITAR Summit, Washington, D.C., June 24-25, 2013
- Co-chair and Speaker, "International Technology Transfers and Deemed Export Compliance: How to Control IT Access and the Flow of Technical Data, and Minimize the Risk of Intangible Export Controls Violations in Defense Services, Cloud Computing and Outsourcing," American Conference Institute's Seventh National Export Controls Forum, San Francisco, California, January 28-29, 2013
- Speaker, "The Export Control Dimension of 'Cloud Computing' and Other Intangible Exports," 25th Annual Global Trade Controls Conference, London, November 13-14, 2012
- "Cloud Computing within Export Controls Limits: Collaborating within Security, Privacy, and Encryption Restrictions," American Conference Institute's 15th National Forum on Global Export Controls Compliance, Washington, D.C., May 23-24, 2012
- Co-chair and Speaker, "Monitoring Technology Transfers in the Context of M&A Transactions: How to Incorporate Effective Safeguards into the Due Diligence, Deal Structure, and Post-Closing Implementation," American Conference Institute's 6th National Forum on International Tech Transfers and Deemed Export Compliance, Washington, D.C., September 26-27, 2011
- "When to Self-Classify or Seek Government Review Under US Encryption Rules: Determining Jurisdiction and Overcoming Complex Classification Challenges," American Conference Institute's 2nd Advanced Summit on Complying with Global Encryption Controls, San Francisco, California, April 12-13, 2011
- "Getting EAR Jurisdiction Right: How to Classify Under the CCL, ECCNs, de minimis Rule and More," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
- "Securing BIS License Approvals: How to Prepare Successful License Applications and Use Key EAR Exceptions," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
- "Implementing a Global Encryption Compliance Strategy: Identifying 'Ancillary Cryptography' and Obtaining U.S. and Foreign Approvals," American Conference Institute's 13th National Forum on Export Controls, Washington, D.C., May 19, 2010
- Co-chair and Speaker, "Protecting Intangibles in Tech Support and R&D Offshoring Ventures," American Conference Institute's 5th National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, September 23-24, 2009
- "When & How to Conduct an Effective ITAR Internal Investigation," American Conference Institute's 4th Forum on ITAR Compliance," Washington, D.C., July 22, 2009
- Lead Panelist and Moderator, "Implementing a Global Export Controls Compliance Program," American Conference Institute's 12th National Forum on Export Controls Global Compliance Strategies, Washington, D.C., May 19-20, 2009
- "Due Diligence: What to Do if Your Good Work Uncovers a Potential Export Controls or Sanctions Violation," American Conference Institute's 11th National Forum on Export Controls, Washington, D.C., May 28, 2008
- "Preparing Government Submissions and Using License Exceptions for Exports and Reexports to China," American Conference Institute's 2nd National International Forum on China Trade Compliance, San Francisco, California, October 16-17, 2007
- "The Ultimate Benchmarking Opportunity: The Export Control Document Swap," American Conference Institute's 10th National Forum on Export Controls, Washington, D.C., May 17, 2007
- "Implementing and Policing an Internal Technology Compliance Program" and "How to Obtain Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Third National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, January 24, 2007
- "The Magic of ITAR Licensing: Preparing DSP-5s, TAAs, and MLAs That Will Impress DTC's Toughest Licensing and Agreements Officers," National Forum on ITAR Compliance, Washington, D.C., June 22, 2006
- "Export Controls," International Corporate Compliance Forum, Plano, Texas, January 19, 2006
- "Meeting the Requirements of the Deemed Export Rule: Key Compliance Challenges and How to Overcome Them" and "Successfully Obtaining Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Forum on Ensuring Compliance with Export Controls on International Technology Transfers, Washington, D.C., June 27-28, 2005, and San Francisco, January 26-27, 2005
- "Do's and Don'ts in Export Classification and Licensing: Techniques for Export Managers," Eighth National Forum on Export Controls, Washington, D.C., April 29, 2005
- "The Complete Guide to Listening under EAR, ITAR, and OFAC: The Magic Is Back," Seventh National Export Controls and Global Trade Compliance Conference, Washington, D.C., April 21, 2004
- "U.S. Export and Re-export Legislation: The Long Arm of U.S. Law," EuroLegal's Conference on Export Controls, London, March 16, 2004
Select Speaking Engagements
- Speaker, “A new geopolitical chess game – how to manage multiplying global sanctions regimes,” 32nd Annual Conference on the Globalisation of Investment Funds, International Bar Association, May 23, 2023
Select Publications
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Co-author, “BIS Expands Export Controls on Advanced Computing Integrated Circuits for Supercomputer and Semiconductor End Use, and on Semiconductor Manufacturing Equipment and Related Equipment to China,” Wilson Sonsini Alert, October 20, 2023
- Co-author with J. Cheng, J. Davey, J. Hartwig, S. Heifetz, T. Jenkins, and A. Seymour, “OFAC Penalizes Another Crypto Asset Company for Sanctions Violations,” Wilson Sonsini Alert, May 22, 2023
- Co-author with K. Millard and S. Patak, “United States Imposes Export Restrictions on Beijing Genomics Institute (BGI) Group Subsidiaries over National Security Concerns,” Wilson Sonsini Alert, March 21, 2023
- Co-author with J. Hartwig and K. Millard, “'Disruptive Technology Strike Force' to Target Protection of Sensitive Technologies, Export Controls Circumvention,” Wilson Sonsini Alert, February 27, 2023
- Co-author with B. Poellot and A. Seymour, “BIS Announces New End-Use Check Policy; Adds YMTC, 30 Additional Chinese Entities to Unverified List,” Wilson Sonsini Alert, October 14, 2022
- Co-author with B. Poellot and A. Seymour, "BIS Implements New Semiconductor- and Supercomputer-related Export Controls and End-Use Controls," Wilson Sonsini Alert, October 13, 2022
- Co-author with K. Millard and A. Seymour, "New Russia Sanctions Imposed as Ukraine War Continues: Expansion of Controls on EAR99 Items and Military End-Uses," Wilson Sonsini Alert, September 19, 2022
- Co-author with K. Millard and A. Seymour, "Russia Sanctions Update: Intellectual Property General License and a Prohibition on the Provision of Some Services," Wilson Sonsini Alert, May 11, 2022
- Co-author with K. Millard and A. Seymour, "New U.S. Sanctions on Russian Banks and Elites, Expanded Export Controls, and Other Updates," Wilson Sonsini Alert, April 11, 2022
- Co-author with K. McDonough and A. Seymour, "License Exception ENC Severely Limited for Exports to Russia and Belarus, Belarus Targeted by Biden’s Third Tranche of Controls, OFAC Clarifies Earlier Restrictions in Russia-Ukraine Crisis," Wilson Sonsini Alert, March 3, 2022
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Co-author with M. Casey, J. Hartwig, K. McDonough, and A. Seymour, "Biden Administration Implements Significant BIS Controls and Imposes Second Tranche of OFAC Sanctions in Russia-Ukraine Crisis," Wilson Sonsini Alert, February 25, 2022
- Co-author with J. Hartwig, K. McDonough, and A. Seymour, "Biden Administration Authorizes New Sanctions on Regions of Ukraine," Wilson Sonsini Alert, February 23, 2022
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Co-author with A. Seymour, "Intrusion Preclusion: BIS Issues Long-Awaited Controls on Cybersecurity Items, Creates New License Exception," Privacy & Cybersecurity Law Report, February-March, 2022
- Co-author with J. Hartwig and A. Seymour, "U.S. State Department Proposes ITAR Revisions to Remove Prior Citizenship Status Considerations," Wilson Sonsini Alert, February 4, 2022
- Co-author with M. Casey, J. Hartwig, S. Heifetz, and A. Seymour, "CJEU Publishes Judgment Interpreting the EU's Blocking Regulation," Wilson Sonsini Alert, February 3, 2022
- Co-author with M. Casey, K. McDonough, and A. Seymour, "2021 U.S. Sanctions Year in Review," Wilson Sonsini Alert, January 13, 2022
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Co-author with J. Hartwig, K. McDonough, and A. Seymour, "Know Your Customer: OFAC, BIS Penalize Companies for Sales of 'EAR99' Items and Services to Prohibited Parties Through Distributors," Wilson Sonsini Alert, September 21, 2021
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Co-author with J. Hartwig, K. McDonough, and A. Seymour, “Electronics Testing Company Penalized $6.6 Million for Unauthorized Software Exports,” Wilson Sonsini Alert, August 19, 2021
- Co-author with A. Seymour, “President Biden Issues Executive Order Amending Restrictions on Chinese Military and Surveillance Companies,” Wilson Sonsini Alert, June 11, 2021
-
Co-author with M. Mannino and A. Seymour, “Take Two: Another Executive Order Addresses U.S. Personal Data Concerns by Prohibiting Business with Companies that Develop or Control Eight Specified Applications with Connections to China,” Wilson Sonsini Alert, January 6, 2021
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Co-author with M. Mannino and A. Seymour, “U.S. Government Authorization Now Required for Certain Business with SMIC and Over 70 Additional Entities in China," Wilson Sonsini Alert, December 19, 2020
- Co-author with J. Gruenspecht, S. Heifetz, M. Mannino and A. Seymour, “As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat,” Wilson Sonsini Alert, September 21, 2020
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Co-author with J. Gruenspecht, M. Mannino, and A. Seymour, “U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That are Prohibited Due to National Security Concerns Raised by TikTok and WeChat,” Wilson Sonsini Alert, September 18, 2020
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Co-author with J. Davey, M. Mannino, and A. Seymour, “Expansion of U.S. Export Controls on Huawei-Designed or Produced Items,” Wilson Sonsini Alert, May 29, 2020
-
Co-author with J. Davey, M. Mannino, and A. Seymour, “License Requirements and U.S. Government Visibility into Exports to China, Russia, and Venezuela Will Increase, but Countries Remain Open for U.S Business,” Wilson Sonsini Alert, May 1, 2020
- Co-author with M. Mannino and A. Seymour, “Artificial Intelligence Software Controlled for Export, Including to Foreign National Employees,” Wilson Sonsini Alert, January 10, 2020
- Co-author with M. Mannino and A. Seymour, “License to Be Required for Exports, Reexports, and Transfers of U.S.-Origin Items to 28 Additional Chinese Entities,” WSGR Alert, October 8, 2019
- Co-author with M. Mannino and A. Seymour, “Export Control Update: 46 Huawei Affiliates Added; License Extended,” WSGR Alert, August 21, 2019
- Co-author with M. Mannino and A. Seymour, “License Required for Exports and Other Items Sent to Huawei and Affiliates,” WSGR Alert, May 17, 2019
- Co-author with J. Gruenspecht, S. Heifetz, M. Mannino, and A. Seymour, “Emerging Technologies to Be Controlled for Export: Comments Due December 19, 2018,” WSGR Alert, November 19, 2018
- Co-author with M. Mannino and A. Seymour, “ZTE Update: Denial of Export Privileges Suspended,” WSGR Alert, July 17, 2018
- Co-author with A. Seymour, “ZTE Update: Order Signed, but Denial of Export Privileges Still is in Effect,” WSGR Alert, June 11, 2018
- Co-author with M. Mannino and A. Seymour, “Denial of Export Privileges Against ZTE Corporation to be Lifted Once Order is Signed,” WSGR Alert, June 6, 2018
- Co-author with M. Mannino, “Reminder: Mandatory Foreign Direct Investment Reports for U.S. Entities Due May 31,2018,” WSGR Alert, May 8, 2018<
- Co-author with M. Mannino and A. Seymour, “ZTE Corporation Sanctioned Again – Prohibitions on Transactions Involving U.S.-Origin Items Effective Immediately,” WSGR Alert, April 18, 2018
- Co-author with D. Glazer, M. Mannino, A. Seymour, and J. Lynch, "Forms Issued for U.S. Mandatory Foreign Direct Investment Reporting," WSGR Alert, March 9, 2018
- Co-author with M. Mannino, D. Glazer and J. Lynch, “Mandatory Reporting for Entities in 2018 Regarding Foreign Direct Investment”, WSGR Alert, Dec 4, 2017
- Co-author with M. Labriola, M. Mannino, and A. Seymour, "OFAC Due Diligence in Securities Offerings," Lexis Practice Advisor, November 16, 2017
- Co-author, "Continuation of ZTE General License Until February 27, 2017," WSGR Alert, November 21, 2016
- Co-author, "U.S. Further Eases Embargo on Cuba," WSGR Alert, October 17, 2016
- Co-author, "BIS Modifies Rules Governing the Export of Information Security Items Under the Export Administration Regulations; Updates to Cuba Regulations Coming Next Week," WSGR Alert, October 14, 2016
- Co-author, "Second Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, August 18, 2016
- Co-author, "Continuation of General License for Exports, Reexports, and Transfers to ZTE," WSGR Alert, June 28, 2016
- Co-author, "Department of Commerce to Ease License Requirement for Exports, Reexports, and Transfers to ZTE as of March 24, 2016," WSGR Alert, March 22, 2016
- Co-author, "License Required for All Exports, Reexports, and Transfers to ZTE Corporation as of March 8, 2016," WSGR Alert, March 7, 2016
- Co-author, "Iran Not Open for U.S. Business: U.S. Trade Embargo Remains in Place; Nuclear Sanctions Lifted," WSGR Alert, January 19, 2016
- Co-author, "Proposed Rule to Subject Certain Cybersecurity Items to Greater Export Restrictions," WSGR Alert, July 9, 2015
- Co-author, "U.S. Companies with Foreign Subsidiary or Affiliate Granted One-Month Extension to File Mandatory Forms," WSGR Alert, June 1, 2015
- Co-author, "Restrictions Eased for Communications-Related Items Exported to Sudan," WSGR Alert, March 24, 2015
- Co-author, "Reporting Requirements for U.S. Companies Regarding Direct Investment," WSGR Alert, March 18, 2015
- Co-author, "U.S. Relaxes the Half-Century-Old Embargo on Cuba," WSGR Alert, January 16, 2015
- Co-author, "Increasing Russian Sanctions Target Financial and Energy Sectors," WSGR Alert, July 21, 2014
- Co-author, "More Restrictions on Business with Russia," WSGR Alert, May 1, 2014
- Co-author, "U.S. Expands Sanctions on Russia in Light of Crisis in Ukraine," WSGR Alert, March 26, 2014
- Co-author with Joshua Holzer, "2008 Olympics in China Pose Legal Risks for U.S. Exporters," The Export Practitioner, Vol. 21, No. 5, May 2007
- "Cloud Computing from A to Z: How to Safely Store Export Controlled Data," 11th Annual Advanced Export Controls Forum on International Technology Transfers, Washington, D.C., February 5, 2019
- "Life Sciences & Export Compliance: Avoid the Pitfalls and Take Advantage of Unique Exemptions and Policies," WSGR event, Boston, July 19, 2018
- "Avoiding Sanctions Risks: How to Navigate OFAC Rules for Web Based Interactions, Cloud Computing, and Shared Networks," ACI's 10th Annual Advanced Forum on Economic Sanctions Enforcement and Compliance, Washington, D.C., April 24, 2017
- "'Technical Data' and the 'Specially Designed' Rule: Group Exercises on How to Apply These Complicated Definitions to Challenging, Real-Life Dilemmas," ACI's Ninth National Export Controls Forum on International Technology Transfers, Cloud Computing and Deemed Exports, Washington, D.C., October 18, 2016
- "Wassenaar: How New Proposals, 2015 Controls, and Countries' Adoption of Note 4 and OAM Affect Your Global Encryption Compliance Strategy," ACI Global Encryption, Cloud & Cybersecurity Controls Conference, San Francisco, March 30, 2016
- Panelist, "Understanding Disclosure: Best Practice," IBC Global Trade Controls & Compliance Conference, London, November 20, 2015
- "Intangible Exports, Cloud Computing, and Export Controls," IBC Global Trade Controls and Compliance Conference, London, November 19, 2014
- Roundtable Speaker with Olga King, "Lessons Learned from the Esterline, Intevac and Meggitt Cases: How to Manage a Government Investigation, Mitigate Exposure and Restore Confidence," Eighth National Export Controls Forum on International Technology Transfers and Deemed Export Compliance, San Francisco, California, September 16, 2014
- "Understanding the Problems of Intangible Exports Including 'Cloud Computing' and Data Transfer," Global Trade Controls and Compliance 26th Annual Conference, London, November 2013
- "Commodity Jurisdiction Determinations: Proven Strategies for Drafting an Effective Request and How to Interpret a DDTC Determination," The ITAR Summit, Washington, D.C., June 24-25, 2013
- Co-chair and Speaker, "International Technology Transfers and Deemed Export Compliance: How to Control IT Access and the Flow of Technical Data, and Minimize the Risk of Intangible Export Controls Violations in Defense Services, Cloud Computing and Outsourcing," American Conference Institute's Seventh National Export Controls Forum, San Francisco, California, January 28-29, 2013
- Speaker, "The Export Control Dimension of 'Cloud Computing' and Other Intangible Exports," 25th Annual Global Trade Controls Conference, London, November 13-14, 2012
- "Cloud Computing within Export Controls Limits: Collaborating within Security, Privacy, and Encryption Restrictions," American Conference Institute's 15th National Forum on Global Export Controls Compliance, Washington, D.C., May 23-24, 2012
- Co-chair and Speaker, "Monitoring Technology Transfers in the Context of M&A Transactions: How to Incorporate Effective Safeguards into the Due Diligence, Deal Structure, and Post-Closing Implementation," American Conference Institute's 6th National Forum on International Tech Transfers and Deemed Export Compliance, Washington, D.C., September 26-27, 2011
- "When to Self-Classify or Seek Government Review Under US Encryption Rules: Determining Jurisdiction and Overcoming Complex Classification Challenges," American Conference Institute's 2nd Advanced Summit on Complying with Global Encryption Controls, San Francisco, California, April 12-13, 2011
- "Getting EAR Jurisdiction Right: How to Classify Under the CCL, ECCNs, de minimis Rule and More," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
- "Securing BIS License Approvals: How to Prepare Successful License Applications and Use Key EAR Exceptions," American Conference Institute's EAR Boot Camp, Dallas, Texas, January 26-27, 2011
- "Implementing a Global Encryption Compliance Strategy: Identifying 'Ancillary Cryptography' and Obtaining U.S. and Foreign Approvals," American Conference Institute's 13th National Forum on Export Controls, Washington, D.C., May 19, 2010
- Co-chair and Speaker, "Protecting Intangibles in Tech Support and R&D Offshoring Ventures," American Conference Institute's 5th National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, September 23-24, 2009
- "When & How to Conduct an Effective ITAR Internal Investigation," American Conference Institute's 4th Forum on ITAR Compliance," Washington, D.C., July 22, 2009
- Lead Panelist and Moderator, "Implementing a Global Export Controls Compliance Program," American Conference Institute's 12th National Forum on Export Controls Global Compliance Strategies, Washington, D.C., May 19-20, 2009
- "Due Diligence: What to Do if Your Good Work Uncovers a Potential Export Controls or Sanctions Violation," American Conference Institute's 11th National Forum on Export Controls, Washington, D.C., May 28, 2008
- "Preparing Government Submissions and Using License Exceptions for Exports and Reexports to China," American Conference Institute's 2nd National International Forum on China Trade Compliance, San Francisco, California, October 16-17, 2007
- "The Ultimate Benchmarking Opportunity: The Export Control Document Swap," American Conference Institute's 10th National Forum on Export Controls, Washington, D.C., May 17, 2007
- "Implementing and Policing an Internal Technology Compliance Program" and "How to Obtain Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Third National Forum on Complying with Export Controls on International Technology Transfers, San Francisco, California, January 24, 2007
- "The Magic of ITAR Licensing: Preparing DSP-5s, TAAs, and MLAs That Will Impress DTC's Toughest Licensing and Agreements Officers," National Forum on ITAR Compliance, Washington, D.C., June 22, 2006
- "Export Controls," International Corporate Compliance Forum, Plano, Texas, January 19, 2006
- "Meeting the Requirements of the Deemed Export Rule: Key Compliance Challenges and How to Overcome Them" and "Successfully Obtaining Deemed Export Licenses, TAAs, and MLAs: A Complete Guide," American Conference Institute's Forum on Ensuring Compliance with Export Controls on International Technology Transfers, Washington, D.C., June 27-28, 2005, and San Francisco, January 26-27, 2005
- "Do's and Don'ts in Export Classification and Licensing: Techniques for Export Managers," Eighth National Forum on Export Controls, Washington, D.C., April 29, 2005
- "The Complete Guide to Listening under EAR, ITAR, and OFAC: The Magic Is Back," Seventh National Export Controls and Global Trade Compliance Conference, Washington, D.C., April 21, 2004
- "U.S. Export and Re-export Legislation: The Long Arm of U.S. Law," EuroLegal's Conference on Export Controls, London, March 16, 2004
Select Speaking Engagements
- Speaker, “A new geopolitical chess game – how to manage multiplying global sanctions regimes,” 32nd Annual Conference on the Globalisation of Investment Funds, International Bar Association, May 23, 2023
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