Export Controls and Cloud Computing: Complying with ITAR, EAR and Sanctions Laws

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, May 10, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide international law counsel with a review of the compliance challenges with export control and trade sanctions laws for cloud users and providers. The panel will offer best practices to meet the International Traffic in Arms Regulation (ITAR), Export Administration Regulations (EAR), and the requirements of the Office of Foreign Assets Control (OFAC).


Storing data in the cloud creates significant legal challenges for companies. Data in the cloud can be located on servers that are housed in different countries. As a result, uploading data to a server outside the U.S., which is considered an export, may require authorization. The location of the users accessing the information and the cloud administrators’ nationality also present compliance risks.

In June 2015, the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) published proposed rules revising key definitions in the EAR and ITAR to harmonize the two export control regimes. The proposed rules would make substantive changes that may determine when items and transactions are subject to U.S. export control rules. The final rules will become effective 30 days after they are published, giving exporters a short time frame in which to make changes to their compliance policies and procedures.

With the prevalence of storing information in the cloud and penalties for violating ITAR, EAR or OFAC restrictions potentially severe, it is critical for companies that use cloud computing services to understand the limitations and requirements when using cloud computing in order to remain in compliance with export control laws.

Listen as our authoritative panel reviews the U.S. export control and trade sanction laws that affect cloud computing, examines the compliance challenges for cloud users and providers, and offers best practices to meet the ITAR, EAR and OFAC requirements.



  1. Applicable export control and trade sanction laws
    1. ITAR
    2. EAR
    3. OFAC/sanctions laws
  2. Compliance challenges
    1. For cloud users
    2. For cloud providers
  3. Best practices for compliance


The panel will review these and other key issues:

  • What guidance have BIS, DDTC and OFAC provided on export control compliance for cloud storage and computing services?
  • What export control compliance challenges do cloud users and providers face?
  • What best practices should cloud users and their counsel employ to ensure compliance with ITAR, EAR and sanctions requirements?


Thaddeus R. McBride
Thaddeus R. McBride

Bass Berry & Sims

Mr. McBride represents companies and individuals in international trade regulatory, compliance, investigative, and...  |  Read More

Christine M. Minarich
Christine M. Minarich
Global Trade Compliance Counsel
Cheryl A. Palmeri, Esq.
Cheryl A. Palmeri, Esq.

Bass Berry & Sims

Ms. Palmeri advises public and private companies on best practices in international trade compliance. She counsels...  |  Read More

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