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

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

Conducted on Wednesday, August 11, 2021

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course 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. Cloud data may be located on servers housed in different countries. As a result, uploading data to a server outside the U.S. is considered an export and may require authorization. The location of the users accessing the information and cloud administrators' nationality also present compliance risks.

The Biden administration has taken actions to further safeguard U.S. technology, including through Commerce Department rules to implement the new information and communications technology and services supply chain transaction review regime.

With the prevalence of storing information in the cloud and penalties for violating ITAR, EAR, or OFAC restrictions potentially severe, companies that use cloud computing services must 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?


Baj, Alexandra
Alexandra (Alex) Baj

Steptoe & Johnson

Ms. Baj focuses her practice on export controls and economic sanctions laws and regulations, anti-corruption...  |  Read More

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

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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