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Steven Brotherton

Steven manages the firm's Export Controls Practice Group with locations in Washington, D.C. and San Francisco, CA. He counsels clients on export control laws and regulations, including compliance with the Export Administration Regulations ("EAR"), International Traffic in Arms Regulations ("ITAR"), and sanctions regulations administered by the Office of Foreign Assets Control ("OFAC").

He advises a wide variety of clients on export control issues, ranging from Fortune 50 companies to mid-size companies and start-ups. Steven has developed and implemented global export compliance programs, led audits, investigations, prepared export licenses and agreements, and has successfully represented companies in connection with government investigations and enforcement actions. Mr. Brotherton is a member the U.S. Department of Commerce’s Regulations and Procedures Technical Advisory Committee (RPTAC), which advises the U.S. Department of Commerce on export control regulation and policy. He is also the Co-Chair of TechAmerica's Export Control Reform Subcommittee.

Representative Experience

Administered the implementation of precedent-setting ITAR consent agreements, including developing State Department mandated corrective actions.

Serves as leading authority on ITAR jurisdictional matters and has obtained favorable EAR determinations on scores of Commodity Jurisdiction applications for technologies utilized in military and space end-uses.

Led State Department mandated ITAR audit of global electronics company, reviewing 25 key manufacturing locations in 5 countries.

Developed and assisted with the implementation of a best-practice Technology Control Plan for Fortune 50 company which, in turn, favorably resolved U.S. government investigation into the client’s deemed export compliance practices.

Prepared export compliance programs for clients ranging from emerging to Fortune 50 companies.

Served as the lead counsel to successfully resolve ITAR jurisdiction issues impacting the global supply chain for the aerospace and automotive industries.

Selected as one of fifteen international participants in an international launch vehicle/satellite failure review and served as export control liaison.

Negotiated U.S. government approval and Congressional certification for multi-billion dollar projects including, in several cases, Presidential approval for exports to China.

Developed and executed strategic export license planning and administration for U.S. military and space programs.

Professional Accomplishments


Member, U.S. Department of Commerce, Bureau of Industry and Services - Regulations and Procedures Technical Advisory Committee (appointed)

Member, American Bar Association, Export Controls and Economic Sanctions Committee

Member, AeA Export Controls Committee

Member, Organization of Women in International Trade

Member, American Council on International Personnel, Export Control Representative

Member, Society for International Affairs

Publications and Lectures

Speaker, American Conference Institute, Global Encryption Controls, "Exploring the Fundamentals of U.S. Encryption Control Regulations," San Francisco, CA, April 2010.

Speaker, "Export Best Practices - The Lifecycle of Export Classification," Organization of Women in International Trade, Northern California, March 2010.

Speaker, American Conference Institute, ITAR Boot Camp, San Diego, CA, February 2010.

Speaker, "Dealing with Jurisdictional Risks in Export Classification," Technology Training Corporation, Defense Export Controls/ITAR, Las Vegas, NV, November 2009.

Speaker, AeA Best Practices Conference, "Export Controls - Hiring, Deployment & Access Issues," September 2009.

Speaker, American Conference Institute, National Forum on Export Controls, "Global Encryption Compliance Workshop," Washington, DC, May 2009.

Speaker, ITAR Hands-On Workshop, Sunnyvale, CA, March 2009.

Speaker, State Bar of California, Immigration and Export Control Issues in Employing Foreign Nationals, Palo Alto, CA, March 2009.

Speaker, Export Control Year in Review, San Francisco Bar Association, San Francisco, January 2009.

Speaker, PAEI ITAR Compliance Conference, Sunnyvale, CA, January 2009.

Speaker, AeA Global Trade Compliance Best Practices Conference, Austin, TX, November 2008.

Speaker, American Conference Institute, International Technology Transfers, San Francisco, CA, “Foreign Nationals: Reconciling Deemed Export and Re-Export Controls with Anti-Discrimination and Privacy Laws,” September 2008.

Speaker, American Conference Institute, National Forum on Export Controls, “China’s Encryption Regulations,” Washington D.C., May 2008.

Speaker, “ITAR Part II: Advanced ITAR Compliance Issues for High-Tech Companies,” Organization of Women in International Trade, Northern California, March 2008.

Speaker, “Technology Transfers in Today’s Global Environment,” Detroit, Michigan, June 2008.

Speaker, “CCL Category 3 Technology Controls,” Professional Association of Exporters and Importers, Santa Clara, CA, April 2007.

Speaker, “Encryption Workshop,” American Conference Institute, Complying with Export Controls on International Technology Transfers, San Francisco, CA, January 2007.

Speaker, “U.S. Export Controls and Technology Transfers,” NCMA World Congress, Atlanta, Georgia, April 2006.

Speaker, “Exporting U.S.-Origin High Technology and Strategic Goods,” Infonex Annual Customs Compliance Conference, Toronto, Canada, February 2006.

Co-Author, “Deemed Export Investigations,” American Bar Association Internal Law Section, March 2005.

Moderator, American Bar Association, Section of International Law, National Audioconference, “Recent Developments in Export Enforcement Cases” March 8, 2005.

Speaker, American Conference Institute, Defense Industry Compliance Conference, “Technology Transfer Workshop”, Washington, D.C., February 25, 2005.

Speaker, Washington Tariff and Trade Letter, National Audioconference, “Deemed Exports and the Employment of Foreign Nationals”, October 2004.

Speaker, Organization of Women in International Trade, Annual Export Controls Conference, “Deemed Exports,” September 2004, Dallas, Texas.

Co-Author, BioProcess International, “Protecting National Security: Changing Workplace Policies on Foreign National Access to Biotech Materials”, BioProcess International, Vol. 1 No. 4, April 2003.