Holland & Hart is recognized as an international leader in export control (ITAR, EAR) and trade sanctions (OFAC) defense and compliance.

The firm’s internationally recognized leadership in this area is due to the balance and sophisticated experience of practitioners with both government and private practice backgrounds.

Holland & Hart's Export Control (ITAR/EAR) and Trade Sanctions (OFAC) Practice features experienced practitioners, former federal prosecutors, and a former attorney from the U.S. Department of Treasury's Office of Foreign Assets Control. This group includes Trip Mackintosh, globally and nationally ranked by Chambers for International Trade: Export Controls and Economic Sanctions; Steve Pelak, a former Principal Deputy Chief and Acting Chief, Counterespionage Section, National Security Division of the U.S. Department of Justice, similarly recognized by Chambers; Amb. (ret.) Timothy Broas, an internationally recognized defense attorney and counselor for multi-national companies; and Jason Prince, a well-established defense and compliance counselor in international trade for exporters and multi-national companies, including one of the world's 10 largest international defense trade companies. They are complemented by a team of attorneys with extensive regulatory, investigatory, and trial skills to provide clients with practical and efficient solutions.

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Export Control (ITAR/EAR) and Trade Sanctions (OFAC) Client Results

Representative Clients and Matters
  • Fortune 50 non-U.S. industrial company with regard to compliance with U.S. Iranian sanctions in global operations

  • Fortune 500 U.S. high technology company with regard to OFAC enforcement action resulting in no penalty resolution as to non-compliant trade with and withdrawal from Syria

  • Non-U.S. company with operations in support of significant military efforts in Iraq 

  • Top 10 global internet and media company with respect to trade compliance in worldwide operations

  • Non-U.S. companies engaged in manufacturing, defense services, transportation and other industries

  • U.S. defense contractor under criminal investigation for alleged unauthorized exports of controlled technical data to China

  • Publicly traded U.S. company with respect to nuclear weapons-related technology exports to China (resulting in a non-penalty resolution)

  • Non-U.S. individual charged with criminal export violations concerning defense articles and an embargoed market

  • U.S. security contractors in Afghanistan and Iraq, with regard to U.S. export controls and the Foreign Corrupt Practices Act

  • Lead counsel in multiple complex settlements with the U.S. State Department, Directorate of Defense Trade Controls, with respect to allegations of violations of the Arms Export Control Act, see published DDTC settlement documents for Xe Services (fka, Blackwater) and Interturbine Logistiks.

  • Defended parties in multiple federal Grand Jury investigations involving the Arms Export Control Act, the Foreign Corrupt Practices Act, the Travel Act, and the International Emergency Economic Powers Act

  • Publicly traded, multi-national engineering and construction service firm with respect to multiple compliance issues, including OFAC (Iranian sanctions), ITAR and EAR requirements and related training

  • Publicly traded, multi-national pharmaceutical company in federal criminal and administrative proceedings concerning the illegal export of missile fuel components controlled by the ITAR

  • U.S. Manufacturer and exporter of ergonomic and other accessories for Category I firearms with regard to ITAR compliance

  • Global manufacturer of armor for vehicles and PPE with regard to ITAR compliance

  • Public traded U.S. company with regard to diversion of clean room technology to Iran

  • Fortune 50, publicly traded company with respect to complex environmental compliance management issues

  • CEO of a Fortune 500 company with respect to a criminal securities investigation

  • High-ranking former executive of an Enron subsidiary with regard to federal prosecution of alleged insider trading and other crimes

  • U.S. company alleged to have criminally violated the Arms Export Control Act through the sale of jet fighter parts to Iran

  • U.S. person alleged to have violated criminal provisions of the International Emergency Economic Powers Act by trading high-technology items with the Chinese Academy of Launch Technologies

  • Non-U.S. national whose testimony was sought by a special Congressional committee and federal Grand Jury investigating ballistic missile technology exports to China

  • Multiple defendants in a federal criminal prosecution alleging violations of export control laws with respect to the export of computers to Syria

Export Control (ITAR/EAR) and Trade Sanctions (OFAC) Publications

Export Control (ITAR/EAR) and Trade Sanctions (OFAC) Speaking Engagements and Events

  • "Tackling Corruption in the Global Arms Trade," Center for International Policy, Washington, DC, November 2, 2017
  • "ITAR Compliance," Rocky Mountain World Trade Center Institute, Denver, CO, October 12, 2017
  • "U.S. Foreign Corrupt Practices Act at 40 – Four Decades of Combatting Bribery Abroad," Panelist (with the Honorable Judge Stanley Sporkin and Jack Blum), discussion presented by Frank Church Institute, Boise State University College of Business and Economics, and Holland & Hart, September 2017
  • "Audit Preparedness 2.0 – Focused Assessment, Quick Response Audits and Audit Surveys: How to Prepare Amid New CBP Expectations and Emerging Risk Factors," American Conference Institute (ACI) Advanced Forum on Customs & Trade Enforcement, Washington, DC, September 25, 2017
  • "ITAR Sections 120.10, 120.17, 124.1, 125.2, 125.3 and 126.18 – How to Comply with Foreign, Dual and Third Country National Rules," American Conference Institute, May 22, 2017
  • "Europe /United-States of America: Export Control of Dual-Use Goods and International Economic Sanctions Outlook for 2017," ICC France Conference, Paris, France, February 6, 2017
  • "Updates on Voluntary Disclosures to the Department of Justice, Criminal Penalties and Personal Liability," C5 Conference on ITAR and the EAR: US Trade Controls Compliance in Europe, Co-Presenter with David Laufman, Chief, Counterintelligence and Export Controls Section, National Security Division, US Department of Justice, London, England, January 31-February 1, 2017
  • "ITAR and the EAR: US Trade Controls Compliance in Europe, Pre-Conference Workshop," C5 Group, Co-Presenter with Candace Goforth, London, UK, January 2017
  • "International Business Transactions: Compliance Challenges and Cross-border Investigations," Association of Corporate Counsel Ethics Day, Denver, CO, December 8, 2016
  • "2016 U.S. Export Controls Compliance Seminar," U.S. Commercial Service, Boise, ID, May 2016
  • "OFAC Sanctions and Compliance," Society for International Affairs – Spring 2016 National Conference, Las Vegas, NV, April 2016
  • "Export Control Enforcement Actions – A Defense Perspective," U.S. Department of Commerce/Bureau of Industry and Security's 2016 Special Agents' Training Conference, Charlottesville, VA, March 2016
Lawyers Ranked in Chambers Global 2018

Triplett (Trip) Mackintosh and Steven Pelak are ranked globally in USA, International Trade: Export Controls & Economic Sanctions

BTI's Law Firms with the Best Collaboration

One of nine firms nationwide named in 2017 by leading legal decision makers for “standout collaboration”

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