Export Controls and Cloud Computing: Complying With ITAR, EAR and Sanctions Laws
Recording of a 90-minute CLE webinar with Q&A
This CLE webinar will provide international trade counsel with a review of the compliance challenges with export control and economic sanctions laws for cloud users and providers. The panel will offer best practices to meet the requirements of the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR) and Office of Foreign Assets Control (OFAC) sanctions regulations.
Outline
- Applicable export control and economic sanction laws
- ITAR
- EAR
- OFAC/sanctions laws
- Compliance challenges
- For cloud users
- For cloud providers
- Best practices for compliance
Benefits
The panel will review these and other key issues:
- What is BIS, DDTC and OFAC guidance 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?
Faculty

Michael T. Gershberg
Partner
Fried Frank Harris Shriver & Jacobson
Mr. Gershberg's practice focuses on the representation of foreign and domestic clients regarding the application of... | Read More
Mr. Gershberg's practice focuses on the representation of foreign and domestic clients regarding the application of economic sanctions and export control laws and regulations, including EAR, ITAR, and economic sanctions administered by the OFAC. He also advises clients on their obligations under the antiboycott and anti-money laundering rules. Mr. Gershberg's work in the export control and economic sanctions area includes advocacy before governmental agencies, conducting internal investigations, and preparing voluntary self-disclosures and other legal submissions. He also assists clients in connection with export transactions and enforcement issues, due diligence for M&As, economic sanctions and export control training, determining export jurisdiction and classification, developing compliance plans and providing compliance counseling, and export licensing.
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Michael A. Grant
Atty
Dechert
Mr. Grant advises clients on matters relating to U.S. national security laws, export controls and sanctions, and trade... | Read More
Mr. Grant advises clients on matters relating to U.S. national security laws, export controls and sanctions, and trade remedies. He focuses his practice on regulatory defense and compliance with sanctions programs promulgated by OFAC and export controls, including EAR and ITAR. In addition, Mr. Grant works on matters relating to trade remedies before CFIUS, Customs and Border Protection and the U.S. Trade Representative. His clients are from an array of industries, including aerospace, banking, defense, energy, financial services, higher education, insurance, manufacturing, pharmaceutical and shipping. Mr. Grant has considerable experience providing counseling, developing license strategies, engineering sanctions compliance programs and negotiating sanctions provisions to U.S. and foreign companies conducting business in OFAC-sanctioned countries.
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Sean Kane
Counsel
Dechert
Mr. Kane advises clients on a broad range of matters relating to U.S. and international economic and trade sanctions,... | Read More
Mr. Kane advises clients on a broad range of matters relating to U.S. and international economic and trade sanctions, anti-money laundering, illicit finance and corruption, internal investigations, and the CFIUS. As the former Deputy Assistant Director for Policy at OFAC in the U.S. Department of the Treasury, Mr. Kane played a key role in implementing high-profile sanction policies and programs involving numerous countries including Iran, North Korea, Russia, Cuba, Syria and Sudan, as well as programs related to counter-terrorism and counter-narcotics. He is an active professional in the international trade community, providing insight for media and regularly featured in articles by national news sites and legal publications.
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Kerry T. Scarlott
Partner
Baker & Hostetler
Mr. Scarlott counsels organizations of all sizes engaging in activities domestically and abroad regarding international... | Read More
Mr. Scarlott counsels organizations of all sizes engaging in activities domestically and abroad regarding international trade matters. He has particularly deep experience counseling technology-based clients on effectively and efficiently navigating EAR, ITAR, FCPA, special sanction programs administered by various U.S. government agencies, OFAC, and national security regulations. Mr. Scarlott regularly represents clients in foreign trade-related matters before U.S. government agencies, including the Departments of Commerce, State, Defense and Treasury. He also has significant experience advising clients on best practices in the development and implementation of compliance policies, procedures and training, as well as experience executing international trade-related due diligence in M&As and financing transactions.
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