Steven C. Emme is a member of the international trade practice.
Practice & Background
Mr. Emme’s practice focuses on international trade, with an emphasis on compliance with U.S. export control regulations, including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). He also has experience with counseling clients on issues involving U.S. sanctions programs administered by the Office of Foreign Assets Control (OFAC).
Before joining the firm, Mr. Emme served as the Senior Advisor to the Assistant Secretary for Export Administration in the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce. Mr. Emme co-drafted regulations implementing President Obama’s Export Control Reform (ECR) initiative, including the initial implementation rule. He also worked on various U.S. Munitions List category rules, including serving as one of the principal authors of revisions to export controls affecting lasers, sensors, infrared detection items and guidance equipment.
Along with drafting regulations implementing ECR, Mr. Emme worked on other aspects of the initiative, including developing the agency’s outreach and educational materials; managing the agency’s participation in reviewing its preparedness to handle the initiative; participating in the interagency ECR Task Force; and briefing various stakeholders on ECR, including other U.S. government agencies, foreign governments, congressional staffers, academic organizations and private sector groups.
In addition to his work on the ECR initiative, Mr. Emme reviewed agency positions on escalated commodity jurisdiction cases and argued several cases before the State Department’s Deputy Assistant Secretary for Defense Trade Controls. He reviewed commodity classification appeals and draft agency determinations. He also led agency efforts to overhaul and streamline support document requirements for license applications to reduce regulatory burden. Mr. Emme worked with the State Department on general correspondence requests and website guidance. He also advised the BIS Under Secretary and Assistant Secretary on talking points, remarks and congressional testimony. Mr. Emme participated in government and private-sector outreach events on export controls and reviewed draft provisions of international trade agreements.
Prior to serving as Senior Advisor at BIS, Mr. Emme was an associate in the international trade group of a major U.S. law firm, where he counseled clients on complying with EAR, ITAR and OFAC regulations. His work included conducting internal reviews, drafting voluntary disclosures, handling jurisdiction and classification reviews, drafting compliance procedures and training organizations on complying with export controls and sanctions. He also handled issues related to U.S. import laws and regulations. Before that, Mr. Emme worked in the Regulatory Policy Division of BIS, where he drafted regulations, handled advisory opinions, and spoke at seminars across the country on export controls.
Mr. Emme received his J.D. cum laude from the University of Minnesota Law School, where he was a member of the Minnesota Journal of Law, Science and Technology. Mr. Emme earned his B.S. from the University of Illinois with highest honors.
- Senior Advisor to the Assistant Secretary for Export Administration, U.S. Department of Commerce, Bureau of Industry and Security (2011–2017)
- Export Policy Analyst, Regulatory Policy Division, U.S. Department of Commerce, Bureau of Industry and Security (2007–2009).