Christopher Stagg wrote and heavily influenced export laws, and he can make a difference through his practical and strategic counsel, as he understands the government’s perspective and opaque agency practices.
From Fortune Global 50 companies to start-ups, Mr. Stagg has advised 100+ companies and organizations on complex and high-stakes issues, including as lawyers of “last resort” to reverse adverse agency decisions.
Christopher Stagg has successfully advocated regulatory changes, originated novel legal arguments that were successfully used in litigation, and wrote the only guide on influencing proposed regulatory revisions.
Christopher Stagg was previously a Senior Policy Advisor at the Directorate of Defense Trade Controls (DDTC), where he re-wrote U.S. export control regulations involving the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), including the U.S. Munitions List and Commerce Control List, and held leadership roles in providing interpretative guidance, handling highly-contested commodity jurisdiction cases, and advising the Federal Bureau of Investigation on export enforcement and national security investigations.
As DDTC's deputy lead for implementing Export Control Reform, Christopher was involved in revising every category of the U.S. Munitions List, amending the Commerce Control List, had responsibility for reviewing and responding to public comments, and developed U.S. policy for designating items as defense articles under the Arms Export Control Act (AECA). Christopher also substantially reformed the ITAR's commodity jurisdiction process - the most significant such effort in history - as he directly revised the government's policies and review procedures for commodity jurisdiction cases.
Since then, he has worked with 100+ companies on all aspects of export controls, including developing the enterprise-wide jurisdiction/classification system for a major defense prime, self-classifying 10,000s of items, successfully resolving commodity jurisdiction cases (including appeals) and enforcement actions, handling internal investigations, and advocating favorable regulatory interpretations.
He is frequently engaged as a lawyer of "last resort" to reverse adverse government actions, as well as primary resort to provide practical guidance. For example, a major defense prime turned to Mr. Stagg to develop a novel legal strategy that successfully resolved a high-stakes export controls matter with the U.S. Government, which if not immediately resolved would have suspended critical global engagements.
Mr. Stagg has been a prominent member of the American Bar Association for nearly a decade, as he is the Vice Chair for Policy of the Export Controls and Economic Sanctions Committee, as well as the Co-Editor of the ABA's Year-in-Review section for export controls and economic sanctions.
Mr. Stagg’s national security experience is further complemented by his experience at Jane’s Information Group, a leading defense information publisher and strategic advisory firm, in its consulting and editorial divisions. At Jane's Information Group, Christopher assessed defense industries, military weapon systems, and emerging technologies. He also reported on defense technologies for Jane's Defence Weekly.
Mr. Stagg has been featured on U.S. export control issues by publications such as Bloomberg, Forbes, Jane's Defence Weekly, WorldECR, and LexisNexis' Law360. He has presented on export controls at the Department of State, the American Bar Association, the Society for International Affairs, the New York City Bar Association, the Export Compliance Training Institute, the Embassy of Canada, and the Embassy of France.
Creating effective and high-confidence strategies and systems for handling export control jurisdiction and classification. Handling individual or large-scale classifications. Advocating whether or how an item should be controlled through commodity jurisdiction or commodity classification (CCATS) requests.
With judicial review rarely an option, the agency appeal is of critical importance to reverse an adverse action; yet, it most often involves highly-opaque government procedures. With our government experience, we provide "last resort" legal counsel in these special situations to seek reversal of adverse agency actions.
With deep experience on both the government and industry side, we help companies advance and protect their interests by developing effective strategies that anticipate and address government concerns. For example, we have worked with clients to ensure that new regulations or a government interpretation would exclude their activities.
An effective risk management and compliance program can save companies significant time and resources by catching potential violations before they occur. We help companies focus on their business activities while having confidence in their compliance systems, which reduces risk and time-consuming, costly investigations.
We help companies identify whether an actual violation of export control laws took place. If so, we advise on corrective actions to reduce further risk of repeat violations. For government investigations, we advise companies on managing the otherwise highly-opaque agency concerns and processes that governs disclosures.
We advise non-U.S. businesses on complying with U.S. export control regulations, such as the applicability of the EAR's foreign direct product and de minimis rules. We also counsel non-U.S. companies on end-use and end-user restrictions, as well as government enforcement actions.
We help clients understand the export control jurisdiction and classification status of encryption items and software under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). We also advise on EAR license exception ENC requirements.
We advise clients on developing and implementing effective strategies to petition for rulemaking or responding to proposed rulemaking, to ensure that new regulations do not adversely affect the client's business interests and that the regulatory agency understands the consequences of any proposed rulemaking.
We advise clients on applying the ITAR's definition of technical data, as well as the term "directly related" on information, software and defense services.
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