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With key experience in both government and industry, Christopher Stagg advises clients on all aspects of U.S. export control laws and particularly involving strategic issues, jurisdiction and classification matters, internal investigations and enforcement defense.
Mr. Stagg’s experience as a senior regulator with the U.S. Department of State and in private practice gives him unique understanding of the successful strategies companies require to navigate export controls and other national security related matters.
Mr. Stagg served with the Directorate of Defense Trade Controls (DDTC) at the U.S. Department of State from 2010 to 2013. In this position he was the deputy lead for the U.S. Department of State on Export Control Reform to rewrite U.S. export control laws under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). This included the most significant update to the entire U.S. Munitions List in thirty years.
Additionally, Mr. Stagg was a leading member of the Commodity Jurisdiction (CJ) section that determines whether items are on the U.S. Munitions List. He was involved in more than 500 CJ determinations and appeals, and authored the government’s procedures and regulations on reviewing requests. Mr. Stagg also authored the U.S. policy on designating and determining items on the U.S. Munitions List within section 120.3 of the ITAR.
As a senior advisor, Mr. Stagg provided actionable guidance on the ITAR to the Federal Bureau of Investigation (FBI), the U.S. Department of Homeland Security, and the Export Enforcement Coordination Center (E2C2) on export enforcement and national security investigations. Christopher worked with federal law enforcement on a multitude of classified and unclassified criminal investigations.
Thought Leadership and Industry Involvement
Mr. Stagg has been featured on U.S. export control issues by publications such as Bloomberg, Jane’s Defence Weekly, WorldECR, and LexisNexis’ Law360. He has presented on U.S. export control laws including Export Control Reform at the U.S. Department of State, the American Bar Association, the Society for International Affairs, the New York City Bar Association, the Embassy of Canada, and the Embassy of France. Christopher is the current co-editor of the American Bar Association’s Year-in-Review for Export Controls and Economic Sanctions, having also previously served as the co-editor in 2014.
Mr. Stagg was previously with a major international law firm in Washington, D.C. where he advised clients on export controls, economic sanctions, the Foreign Corrupt Practices Act (FCPA), international aviation law, foreign investment in the United States (CFIUS) and other national security issues, such as the Economic Espionage Act, the Foreign Intelligence Surveillance Act (FISA) and responding to national security letters.
Prior to a legal career, Mr. Stagg was with Jane’s Information Group. At Jane’s, he was as a reporter for Jane’s Defence Weekly covering the international defense industry and Operation Iraqi Freedom. He was also with Jane’s Strategic Advisory Services as an analyst and a consultant where he assessed foreign militaries, defense industries, weapons systems, telecommunication networks, and energy infrastructure projects.
Mr. Stagg received his law degree from Saint Louis University School of Law with a concentration in business transactional law. He received his bachelor’s degree from George Washington University in international politics with a focus on the U.S.-Japan security alliance. He also studied at the London School of Economics, the Yamasa Institute in Japan, and the Foreign Service Institute for classified coursework on intelligence and foreign policy.
- Deeply involved in the interagency reviews for revising the U.S. Munitions List and the creation of the new “600 Series” on the Commerce Control List, including analyzing and responding to public comments in Federal Register notices.
- Served as a leading member of the commodity jurisdiction team, which involved handling more than 500 commodity jurisdiction reviews. Developed new internal review standards for the commodity jurisdiction process and chaired interagency meetings.
- Authored the new U.S. policy on designating and determining defense articles and defense services as codified in 22 CFR 120.3, as well as revised the commodity jurisdiction procedure as codified in 22 CFR 120.4. Contributed to the new definitions of “specially designed” and “software” under Export Control Reform.
- Advised the Federal Bureau of Investigation’s counterintelligence division on national security investigations and issues concerning the Arms Export Control (AECA) and the International Economic Emergency Powers Act (IEEPA).
- Rewrote review methods and provided guidance to Customs and Border Protection through the EXODUS program on outbound detentions of items that may be controlled on the U.S. Munitions List or Commerce Control List.
- Oversaw internal implementation and training on Export Control Reform. Provided Export Control Reform training to the U.S. Department of Homeland Security, including Customs and Border Protection and Immigration and Customs Enforcement.
- Represented the United States in bilateral and multilateral discussions with foreign governments both abroad and at embassies in Washington on Export Control Reform and other matters related to U.S. export control laws.
- Monitored legal developments involving export control laws to present senior management with forward-looking legal guidance, background papers, and proposed regulatory changes.
- Authored advisory opinions to foreign governments, U.S. companies, and individuals on interpretative guidance of the International Traffic in Arms Regulations (ITAR).
- Frequent U.S. Government speaker on Export Control Reform and U.S. export control laws at government and industry events.
- Represented numerous companies in successful appeals and requests of reconsideration of Commodity Jurisdiction determinations, which resulted in moving the items from the U.S. Munitions List to the Commerce Control List.
- Advised non-U.S. companies on the applicability of the ITAR and EAR on products that incorporate U.S. origin goods and information to avoid potential export control violations.
- Established corporate export control compliance programs for numerous U.S. small business entities that provide export controlled goods and services, including encryption software subject to the ITAR and EAR.
- Assisted numerous U.S. defense companies on revising and updating existing corporate export compliance programs to handle the regulatory requirements under Export Control Reform.
- Advised U.S. defense information publisher on the ITAR’s requirements for the use and dissemination of public domain information, including an assessment of the jurisdiction and classification of proposed new products.
- Assisted clients with high-level and interagency advisory opinion requests to the Department of State for clarifying interpretations of the ITAR, the impact of which would materially affect the clients’ business operations.
- Advocated client positions in responses to proposed federal rules published in the Federal Register involving the ITAR and EAR to protect the client’s interests.
- Carried out an internal investigation of a U.S. defense company involving the potential violations of the ITAR and EAR.
- Advised numerous U.S. defense companies on the new brokering requirements and whether certain transactions constituted brokering activities under the ITAR.
- Reviewed technical assistance agreements (TAA) and manufacturing licensing agreements (MLA) of a U.S. defense prime contractor to ensure compliance with the ITAR, the Agreements Guidelines, and revisions under Export Control Reform.
Awards & Honors
- Export Control Reform, U.S. Department of State (2013)
- National Security Investigations, U.S. Department of State (2013)
- ICE Director’s Award for Counterproliferation Investigations, U.S. Department of Homeland Security (2013)
- Export Enforcement, U.S. Department of Homeland Security (2013)
- Commodity Jurisdiction, U.S. Department of State (2011)
- Presented on “ITAR and EAR Harmonization Rule – Preparing Comments” with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce, Edward Peartree of the U.S. Department of State and Jahna Hartwig of Sikorsky Aircraft Corporation for the American Bar Association (ABA) on July 21, 2015 in Washington, D.C.
- Presented on “”Responding to the State Department’s Proposed ITAR Prior Approval Requirement for Public Domain Information,” in Washington, D.C. on July 8, 2015.
- Presented on “Export Controls: Administrative Law and Rulemaking,” at the Impact of Export Controls on Higher Education & Scientific Institutions conference in Washington, D.C. on June 9, 2015.
- Presented with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce on “Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules,” in Washington, D.C. on February 25, 2015.
- Presented on “ITAR to EAR: Mastering the Complexity and Maximizing the Benefits of the New Reform Rules” at The Knowledge Group’s webinar on February 9, 2015.
- Presented on “Export Control Reform” and “ITAR Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on January 22, 2015.
- Presented at NAITA’s Export Control Roundtable on “Jurisdiction and Classification: State or Commerce? Has My Jurisdiction Changed as a Result of Export Control Reform?” in Huntsville, Alabama on December 4, 2014.
- Presented on “Export Control Reform” with Todd Willis of the U.S. Department of Commerce at SRA International’s Managing the Legal & Regulatory Research Landscape Conference in Washington, D.C. on June 19, 2014.
- Presented on “Reclassifications of Controlled Goods: Incorporating US Export Control Reform, the Wassenaar Arrangement and EU Export Control Reforms into Your Approach” at C5’s 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014.
- Presented on “US Export Control Reform Update: How to Prioritise your Compliance Approach to Operate under the EAR and Handle the Latest Reforms”at C5’s 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014
- Presented on “Export Controls and Space Research” at the Second Annual Impact of Export Controls on Higher Education and Scientific Institutions conference in Atlanta, GA on May 6, 2014.
- Presented on “Classification Post Export Control Reform” at the Society of International Affairs Conference on Export Control Reform in New Orleans, LA on May 5, 2014.
- Presented at the Embassy of Canada on “Export Control Reform: New Approaches and Opportunities for the Satellite Industry” in Washington, D.C. on March 12, 2014.
- Presented at the American Bar Association’s CLE on export controls and economic sanctions in Washington, D.C. on January 22, 2014.
- Presented on “Advanced ITAR Issues: Practical Strategies For Managing Export Control Reform” in Washington, D.C., Dec. 17, 2013.
- Presented at the December meeting of the New York City Bar Association’s International Trade Committee on “Export Controls, Economic Espionage, and National Security” in New York, NY, Dec. 3, 2013
- Presented at the National Academies’ Government-University-Industry Research Roundtable in Washington, D.C. on “Understanding Research Globalization in the Context of National Security and Prosperity,” Oct. 22, 2013
- Presented at the Embassy of France in Washington, D.C. on “Export Control Reform,” Oct. 11, 2013.
- Presented at the Embassy of France in Washington, D.C. to “An Overview of U.S. Export Control Laws,” Sept. 26, 2013.
- Presenter, “Addressing Classification and Jurisdictional Determinations,” ITAR Summit, Momentum Events, June 2013.
- Guest Lecturer, “The Lachmann Case and Specially Designed: Applications of Constitutional Law to Export Controls,” Georgetown University Law Center, June 2013.
- Presenter, “Update on Export Control Reform,” Private Conference, May 2013.
- Presenter, “Overview of the Commodity Jurisdiction Procedure,” U.S. Department of State In-House Training, March 2013.
- Presenter, “Export Control Reform: An Update and Primer,” ITAR Compliance Conference, Marcus Evans, Feb. 2013.
- Presenter, “Commodity Jurisdiction: Practical Tips and Considerations,” Private Conference, Sept. 2012.
- Co-Editor, Export Controls and Economic Sanctions: Year-in-Review for 2014, American Bar Association, Spring 2015.
- Authored “DDTC’s Arms Export Control Act Problem (In re: ITAR Proposed Rule on Prior Approval for Public Domain Information),” June 16, 2015.
- Authored “Toolkit for Writing Public Comments on Export Control Reform,” May 4, 2015.
- Authored “DDTC Advances Proposed Rule for Cloud Computing, Defense Services, Technical Data, Public Domain, and Product of Fundamental Research,” April 30, 2015.
- Authored “Status Update on Export Control Reform,” April 22, 2015.
- Authored “Court Case Reveals Insights into the Commodity Jurisdiction Procedure,” March 16, 2015.
- Authored “DDTC Requests Public Comments on USML Categories VIII and XIX: Practical Tips for Preparing Effective Comments,” March 2, 2015.
- Authored “The Curious Case of Technical Data as a Defense Article – And Potential Consequences for Cloud Computing,” Feb. 19, 2015.
- Authored “The Strategic Commodity Jurisdiction (CJ) Request,” Feb. 16, 2015.
- Authored “DDTC Issues Overly Expansive Interpretation of the ITAR for Defense Services (and Presumably Technical Data),” Dec. 8, 2014.
- Authored “Influencing Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules,” Dec. 1, 2014.
- Co-Editor, Export Controls and Economic Sanctions: Year-in-Review for 2013, American Bar Association, Spring 2014.
- Authored “Export Control Reform: A Review And Look Ahead” for LexisNexis Law360, Dec. 19, 2013.
- Quoted for Export Control Reform by Bloomberg BNA in “Final Rules Now Effective Revising Controls For Items Related to Aircraft, Turbine Engines,” Oct. 15, 2013.
- Export Controls (ITAR & EAR)
- Export Enforcement Defense
- Administrative Law & Rulemaking
- Constitutional Law
- Foreign Military Sales
- Internal Investigations
- U.S. Department of State
- Williams Mullen P.C.
- Jane’s Information Group
- American Bar Association
- New York City Bar Association
- Society for International Affairs
- District of Columbia
- New York
- U.S. District Court for the District of Columbia
- U.S. District Court for the Southern District of New York