Steve assists clients with internal corporate compliance and due diligence efforts with regard to export controls, sanctions, anti-corruption, anti-money laundering, national security, and other statutes and regulations, including the Arms Export Control Act/International Traffic in Arms Regulations (ITAR); the Export Administration Regulations (EAR); the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) sanctions programs; the Foreign Corrupt Practices Act (FCPA); the Committee on Foreign Investment in the United States (CFIUS); the Foreign Agents Registration Act (FARA); anti-money laundering (AML) laws and other federal regulatory schemes. In 2018 and again in 2020, the Assistant Secretary of Political-Military Affairs, U.S. Department of State, appointed Steve to serve as a member of the Defense Trade Advisory Group (DTAG) during the 2018-2020 and 2020-2022 DTAG terms. DTAG advises the Department of State on its administration and enforcement of the ITAR and its regulation of international defense sales to protect and advance the foreign policy and national security interests of the United States, while reducing impediments to legitimate exports.
Prior to joining Holland & Hart in June 2013, Steve served as the U.S. Department of Justice's National Coordinator for Export Controls/Sanctions Enforcement from 2007 until 2013. During those years with the Justice Department, Steve also served as the Acting Chief and Principal Deputy Chief of the Counterespionage Section of the National Security Division.
In those roles, Steve directed a national program of federal prosecutors and investigators to enhance and increase the U.S. government's ability to investigate and prosecute export control and sanctions violations. Leading the Justice Department's export controls/sanctions enforcement activities and public outreach efforts, Steve has a deep understanding of the U.S. government's policies and enforcement of national security trade laws and regulations, including the current and emerging policies and priorities of federal administrative and law enforcement agencies.
In addition, Steve served for 18 years as an Assistant United States Attorney in the U.S. Attorney's Office for the District of Columbia in a wide variety of capacities. He handled numerous federal investigations and prosecutions involving fraud, bribery, export control and sanctions offenses, public corruption, labor union embezzlement and corruption, national security offenses, and overseas terrorist acts against U.S. citizens. He served as lead counsel on dozens of jury trials and appellate arguments before the U.S. Court of Appeals for the District of Columbia Circuit, the U.S. District Court for the District of Columbia, the Court of Appeals for the District of Columbia, and the Superior Court of the District of Columbia.
Steve’s experience in export controls, sanctions, FCPA, national security, CFIUS, FARA, AML, and public corruption matters allows his clients a unique and wide perspective on a range of important U.S. Government regulatory, investigative, and enforcement initiatives and actions.