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

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

Conducted on Thursday, April 4, 2019

Recorded event now available

or call 1-800-926-7926
Program Materials

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.


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 cloud administrators' nationality also present compliance risks.

In November 2018, with mounting national security concerns, the current administration took the first steps toward imposing new export controls on emerging technologies, including those in high technology sectors.

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 to remain in compliance with export control laws.

Listen as our authoritative panel reviews the U.S. export control and economic sanction laws that impact 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 economic 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 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?


Gershberg, Michael
Michael T. Gershberg

Fried Frank Harris Shriver & Jacobson

Mr. Gershberg's practice focuses on the representation of foreign and domestic clients regarding the application of...  |  Read More

Grant, Michael
Michael A. Grant


Mr. Grant advises clients on matters relating to U.S. national security laws, export controls and sanctions, and trade...  |  Read More

Kane, Sean
Sean Kane


Mr. Kane advises clients on a broad range of matters relating to U.S. and international economic and trade sanctions,...  |  Read More

Scarlott, Kerry
Kerry T. Scarlott

Baker & Hostetler

Mr. Scarlott counsels organizations of all sizes engaging in activities domestically and abroad regarding international...  |  Read More

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