Kay Georgi

Partner – Arent Fox, Washington DC


Kay Georgi has more than 23 years’ experience advising clients on all aspects of international trade, with particular capability in the areas of export control and sanctions, Foreign Corrupt Practices Act (FCPA), and import (customs) matters.  Ranked as one of the nation’s leading International Trade: Export Controls & Economic Sanctions lawyers by Chambers USA, and as a leading international trade practitioner by Legal 500 and Expert Guides, Kay is known for helping large and small clients understand, comply with, and weather the investigation storms associated with the complicated set of US laws and regulations governing US exports and non-US reexports of goods, software, services, and technology. Some of Kay’s recent engagements:

  • Lead auditor in International Traffic in Arms Regulations (ITAR) audits conducted pursuant to the Directorate of Defense Trade Controls (DDTC) of the Department of State consent agreement/directed disclosures
  • Expert witness on the ITAR in international arbitration
  • Advisor to non-US companies responding to US criminal and civil government inquiries related to non-US trade in dual use goods/services with US embargoed countries
  • Conduct global reviews of  Fortune 500 companies export and import compliance programs and provide training to those companies
  • Provide counseling and investigative experience and assistance in voluntary and directed disclosures to a wide range of industries.

Client Work

Kay has significant experience on export control matters, including advising clients on US and international laws relating to the export and import of defense articles, services, and technologies, as well as dual-use goods and technologies, and nuclear equipment and technologies. She regularly represents clients before the Bureau of Industry and Security (BIS) of the Department of Commerce, the DDTC of the Department of State, and the Office of Foreign Assets Control (OFAC) of the Department of Treasury. She is experienced in the management and resolution of:

  • Licensing
  • Commodity jurisdiction and classification requests
  • Internal and external audits
  • Voluntary and not-so-voluntary disclosures
  • US government investigations

Kay has particular industry knowledge in the areas of:

  • Defense
  • Aircraft/aerospace/space
  • Medical devices
  • Telecommunications and encryption & security
  • Crime control
  • Electronics & computers and memory
  • Freight forwarding
  • Security services
  • Oil, oilwell services, and petroleum exploration
  • Global positioning and surveying
  • Industrial manufacturing products

Kay also advises clients regarding compliance with anti-corruption laws, including the FCPA, and assists in internal and US government investigations relating to the FCPA and commercial bribery.  More recently, Kay has advised clients on compliance with US customs related laws and regulations administered by the Customs and Border Protections (CBP).

Previous Work

Kay formerly was an associate and partner from 1989 to 2005 with Coudert Brothers LLP.

Professional Activities

Kay is a member of the American Bar Association (ABA), Section of International Law and Practice, and serves as Immediate Past Co-chair of the ABA Export Controls & Economic Sanctions Committee.  She is also a member of the New York State Bar Association.


Kay is co-editor of the ABA Handbook of Export Controls & Economic Sanctions (2013).  She also co-authored “The More Than You Ever Wanted to Know about Iran Sanctions Chart: Key prohibitions of ITRSHRA, CISADA, NDAA, the Iran Sanctions Act, Executive Orders, and Much More” published in Practicing Law Institute (PLI) Coping with U.S. Export Controls (2012) and “The Arab Spring and OFAC’s Targeted Sanctions,” published in PLI Coping with U.S. Export Controls (2011). She also authored a chapter in the ABA International Practitioner’s Deskbook Series, Joint Ventures in the International Arena, Second Edition, titled “International Trade Considerations in International Joint Ventures” (2010). Additionally, she wrote “A Brief Summary of Customs and Trade Issues” for the Metropolitan Corporate Counsel (July 2005). Kay also co-authored chapters on safeguards and trade considerations in the ABA International Practitioner’s Deskbook Series on Trade Remedies (2006).

Kay has been recognized by Chambers USA as one of the nation’s leading International Trade: Export Controls & Economic Sanctions lawyers. Kay has also been recognized as a leading international trade practitioner by Legal 500Expert Guides, and Who’s Who Legal.

Kay’s recent speaking engagements include:

  • “An Inside Look at The Evolving OFAC Licensing Process, Timeline and Criteria: How New, Tightened Sanctions Affect Your Chances of Approvals,” ACI Economic Sanctions Bootcamp, December 4, 2013
  • “Managing ITAR/Export compliance reform for defense electronics suppliers,” Military Embedded Systems Webinar, November 12, 2013
  • “Expansion of the Extraterritoriality of Iran Sanctions,” C5 Advanced Forum on Economic Sanctions,  Amsterdam, NL May 15, 2013
  • “Export Disclosures – When, Why, and How to Make Them,” Association of Corporate Counsel (ACC) Western Pennsylvania Chapter Forum on Disclosures In The Import/Export Arena, Pittsburgh, PA, May 7, 2013
  • “The Ins and Outs of Classifying Under Part 810 of DoE, Part 110 of NRC and the EAR,” American Conference Institute (ACI) 3rd Annual Summit on Complying with Nuclear Export Controls, Washington, DC, March 19, 2013
  • “When Software Development, Technical Support and Other Assistance Become ITAR-Controlled ‘Defense Services’ – When and How to Secure a TAA to Prevent Penalties and Uninterrupted Business,” ACI Forum on International Technology Transfers and Deemed Export Compliance, San Francisco, CA, January 28, 2013
  • “Case Studies — Hard Questions and Issues Encountered (Almost) Every Day,” PLI’s Coping with US Export Controls 2012, Washington, DC, December 10-11, 2012
  • “Navigating the Foreign Corrupt Practices Act, Export Controls and Embargoes Maze: Key Issues Facing California Businesses,” with Mary Carter Andrues and Stephen Larson, FCPA/Export Controls and Economics Roundtable, Ontario, CA, October 18-19, 2012
  • “US Export Regulations Regarding Communications Intercept Equipment Software and Technology,” ISS World Americas 2012, Bethesda, MD, October 12, 2012
  • “Export Controls and the NISPOM,” with Craig King, NCMS 48th Annual Training Seminar, Orlando, FL, June 12-13, 2012
  • Expeditors Global Logistics Council, Seattle, WA, May 16, 2012
  • The Practicing Law Institute’s Coping with US Export Controls 2011, “Treasury Department Economic Sanctions: Winds of Change Across the Globe,” Washington, DC, December 2011
  • “Preventing Unauthorized Technology Transfers for Offshore Outsourcing of Manufacturing, R & D and Services: Tailoring Your Contracts and Global IT Space to the Level of Controlled Technology and Third Party Risk,” American Conference Institute’s 6th National Forum on International Technology Transfers and Deemed Export Compliance, Washington, DC, September 2011
  • “Top 10 Export Compliance Tips,” NDIA’s International Trade for Defense, Aerospace and Technology Companies Program, Parker, CO, September 2011
  • “The Fundamentals of ITAR Compliance in Practice: Key Concepts and Requirements Under the International Traffic in Arms Regulations,” C5’s ITAR Compliance in Europe Conference, Munich, Germany, June 15-16, 2011
  • Singapore Summit on Export Controls Compliance, Singapore, October 2010
  • “Determining ITAR Export Jurisdiction: How to Obtain a Commodity Jurisdiction (CJ),” C5’s 3rd Annual ITAR Compliance in Europe, Munich, Germany, June 2010
  • “Dealing with Unique Export Controls Issues Affecting Manufacturing, R & D and Repair Centers Overseas,” ACI’s National Forum on Export Controls, Washington, DC, May 2010
  • American Conference Institute’s ITAR Boot Camp, Orlando, FL, October 2009
  • “ITAR and Other Export Issues from a Small Business Perspective,” Military and Aerospace Electronics Forum, San Diego, CA, June 2009
  • American Conference Institute’s ITAR Boot Camp, San Diego, CA, February 2009
  • US Commercial Service’s Export Controls and Compliance Workshop, Pittsburgh, PA, October 2008
  • “Obtaining Deemed Export Licenses, TAAs and MLAs: Key Requirements and Exceptions,” Complying with Export Controls on International Technology Transfers, San Francisco, CA, September 2008
  • American Conference Institute’s 3rd National Forum on Export Enforcement & Investigations, Washington, DC, January 2008

Bar and Court Admissions

  • District of Columbia Bar
  • New York Bar
  • US Court of International Trade
  • US Court of Appeals, District of Columbia Circuit
  • US Court of Appeals, Federal Circuit
  • US Court of Appeals, Fourth Circuit
  • US Court of Appeals, Fifth Circuit


  • Cornell Law School, JD, international legal affairs (summa cum laude), 1989
  • Cornell University, BA, classics and archeology (distinction), 1985

Life Beyond the Law

Kay enjoys playing euphonium in local bands, gardening, motorcycle touring, and CrossFit (CrossFit Level 1 trainer).

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