Compliance:
U.S. Export Control and Sanctions Laws

Compliance: U.S. Export Control and Sanctions Laws

BTC Law represents U.S. and foreign companies on all aspects of export licensing and regulatory issues involving the Export Administration Act, the Foreign Assets Control Regulations, the International Traffic in Arms Regulations, the Trading with the Enemy Act and the International Economic Emergency Powers Act.  BTC Law's founding member, Mr. Andy R. Camacho, brings his national security experience in this area through his work in Europe, Asia, and Latin America.

Dual-Use Products and Technology

​​

BTC Law has experience in navigating the complex issues involved in exporting “dual-use” products and technology. We assist companies, both foreign and domestic, on issues ranging from criminal investigations of alleged export violations to developing compliance programs.

In advancing our clients' interests, we work closely with officials at the Department of Commerce Bureau of Industry and Security (BIS), the principal agency that administers and enforces export controls on commercial goods under the Export Administration Regulations. We assists clients entering the export market in determining if their products are classified under the Commerce Control List, determining whether and how certain exemptions apply, and providing advice with export clearance procedures. We also work hand-in-hand with in-house export compliance staff in developing export compliance policies and procedures tailored for that company.  Some of our areas of experience include:

​

• advise companies on U.S. re-export restrictions on U.S. goods, and inter-relation between BIS rules and OFAC rules;

• advise clients on “deemed” export regulations affecting certain foreign employees of U.S. companies;

• draft compliance procedures;

• counsel clients on all aspects of the voluntary disclosure process in connection with potential export violations; 

• represent clients under criminal and civil investigation for alleged export violations; and

• coordinate defense including in cases with multiple federal investigative agencies involved (e.g., Federal Bureau of Investigation, Homeland Security, Justice, BIS). 

​

Defense Trade

​

We represent companies in connection with export controls under the International Traffic in Arms Regulations (ITAR). We guide clients on changes in policy and practice at the State Department, Directorate of Defense Trade Controls and provide advice on issues ranging from licensing to voluntary disclosures.

Since the ITAR applies not only to military equipment, but also to a range of other technologies, including commercial satellites and certain geodetic data, we assist companies in navigating this area of export compliance.

Economic Embargoes/Sanctions

We advise domestic and foreign companies on a wide range of issues relating to U.S. economic embargoes, including guiding our clients with the Treasury Department Office of Foreign Assets Control (OFAC) issues.

Compliance with embargo laws often involves complex questions of jurisdiction, and is further complicated by the applicability of different laws and regulations to each embargoed country. We work with our clients on issues ranging from implementation of transaction screening procedures to representation in criminal and civil investigations of potential violations.

​​

​​

​​

​

​

​

​​