Steve’s practice focuses on international trade and national security, with an emphasis on compliance with U.S. export control regulations, including the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). He also has experience with counseling clients on issues involving U.S. sanctions programs administered by the Office of Foreign Assets Control (OFAC).

Steve served in BIS in different capacities during the Biden-Harris and Obama Administrations. In the Biden-Harris Administration, he first served as Chief of Staff and then most recently as Chief Strategy Officer and Counselor to the Under Secretary of Commerce. In those roles, he led the policy and strategic planning of the agency and played a key role in developing new frameworks for controlling critical technologies related to semiconductor production and design, biotechnology, advanced computing, and artificial intelligence. He was also involved in the development of export controls related to Russia and Belarus sanctions, firearms, standards-related activities, Validated End User program, Entity List policies, and plurilateral controls implemented by international partners. Additionally, Steve led efforts to enhance BIS’ analytical assessments, decision-making procedures, and technical expertise to more effectively address complex geopolitical events and advancements in critical technologies. He also evaluated appeals related to license applications and temporary denial orders.

During the Obama Administration, Steve served as the Senior Advisor to the Assistant Secretary for Export Administration at BIS. In that role, he worked with the Departments of State, Defense, Treasury, and Homeland Security as part of the interagency task force on the Export Control Reform (ECR) Initiative. He co-drafted regulations implementing ECR, including the initial implementation rule. He also worked on various U.S. Munitions List category and corresponding Commerce Control List rules, including serving as one of the principal authors of revisions to export controls affecting lasers, sensors, infrared detection items and guidance equipment. In addition, he reviewed escalated commodity jurisdiction cases, which were often complicated cases for which there was no initial interagency consensus.

In private practice, Steve has helped clients navigate dynamic and evolving international trade requirements. He has extensive experience guiding clients in the semiconductor, computing, sensor, aerospace, medical, energy, biotechnology, defense, and other industries on handling U.S. export control requirements, including the application of U.S. extraterritorial controls on multinational and non-U.S. operations. He has advised on compliance procedures, including those related to Department of State consent agreements, managed the preparation and submission of numerous license applications for high-value transactions, and conducted compliance reviews to address potential violations of U.S. requirements.      

With key experience in both private practice and the government, Steve provides guidance to clients from a diverse range of industries on interpreting and complying with international trade regulations. His experience includes:

• Handling classification reviews, including conducting self-classifications, drafting commodity jurisdiction requests to the Directorate of Defense Trade Controls (DDTC), drafting classification requests to BIS, and reviewing applicability of U.S. export controls to non-U.S. origin items.
• Drafting license applications and other authorization requests for submission to BIS and DDTC.
• Conducting investigations and drafting voluntary disclosures to BIS and DDTC.
• Constructing procedures and training materials for complying with U.S. export controls and sanctions.
• Conducting international trade due diligence in mergers and acquisitions.