35 North Lake Avenue, Suite 710, Pasadena, CA

Practice areas

Export Controls & Sanctions Compliance

Export classification and licensing analysis under the EAR, restricted-party and end-use due diligence, OFAC sanctions review, investigations and voluntary self-disclosures.

Whether an export is permitted depends on the item, the destination, the parties and the intended use. We help companies analyze transactions before they happen and respond when a question arises after the fact.

Scope of representation

  • Export Administration Regulations (EAR) classification (ECCN) and licensing analysis
  • Restricted-party, end-user and end-use due diligence
  • OFAC sanctions, embargoes and high-risk transaction review
  • Investigations, enforcement inquiries and voluntary self-disclosures
  • Internal compliance procedures and training

Classification and licensing

Export-control and sanctions questions arise in shipments, re-exports, technology access, services and payments. We separate jurisdiction, classification and transaction-specific restrictions, and support classification with technical facts rather than a commercial product name.

Counterparties, end users and payment flows

Review goes beyond the customer’s name to ownership, intermediaries, delivery routes, end users, stated applications and the financial channels used. A single database search is not a complete legal analysis; we document whether to proceed, ask for more information, or pause.

Investigations and disclosures

Early priorities are preserving records and understanding the full transaction history. We evaluate agency correspondence, corrective steps and whether a voluntary disclosure merits consideration, and help put screening, escalation and recordkeeping procedures in place.

How a matter proceeds

  1. Map the transaction. Item, technology, destination, parties, payment route and intended use.
  2. Analyze controls. Classification, license requirements, exceptions and list screening.
  3. Act on the result. Proceed, obtain a license, restructure, or prepare a disclosure.

Timing and fees

Timing depends on the notice, the agency or court, and the facts. Response dates stated in a notice are reviewed individually as soon as we receive it. Scope, fees and any deposit are discussed before we are engaged and confirmed in a written engagement letter.

Facing a deadline? Call (520) 358-5095. An online appointment request does not extend any government or court deadline.

Documents for an initial review

  • Technical specifications and any existing ECCN or classification support
  • Contracts, invoices, shipment routes and payment arrangements
  • Party names, ownership information, end-user and end-use statements
  • Agency correspondence and a complete transaction chronology

E-mail copies to info@attorneywu.com with the subject “Your name – short description”. Please do not send documents through the chat or the booking form.

Frequently asked questions: export controls and sanctions

Does my product need a U.S. export license?

It depends on the item’s Export Control Classification Number (ECCN) under the Export Administration Regulations (EAR), the destination, the end user and the end use. Parties should also be screened against U.S. restricted-party lists such as the Entity List and OFAC’s SDN List. If a violation may have occurred, a voluntary self-disclosure can reduce penalties.

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We found a past export mistake. Should we disclose it?

Possibly. Voluntary self-disclosure to the Commerce Department (BIS) or to OFAC is generally treated as a significant mitigating factor and can reduce or avoid penalties. The decision depends on the facts, the items, the parties and whether the agency already knows. Before you disclose, stop further shipments of the same kind, preserve records, and have counsel review what happened.

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General information only, not legal advice. Book a consultation for advice on your situation.

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