Christopher B. Stagg

Contact Information

(202) 771-7579

chris@stagg.law

Practice Areas

  • Export Controls
  • ITAR Issues & Appeals
  • EAR Issues & Appeals
  • Economic Sanctions
  • CFIUS

Admissions

  • District of Columbia
  • New York
  • U.S. Court of Appeals for the Second Circuit
  • U.S. District Court for the Southern District of New York
  • U.S. District Court for the District of Columbia

Education

  • J.D., Saint Louis University
  • B.A., George Washington University

Honors

  • Highly Commended for U.S. Export Controls, WorldECR
  • Appreciation Award for Export Control Reform, U.S. Department of State
  • Appreciation Award for National Security Investigations, U.S. Department of State
  • ICE Director’s Award for Counterproliferation Investigations, U.S. Department of Homeland Security
  • Appreciation Award for Commodity Jurisdiction, U.S. Department of State

With the unique experience of writing and heavily influencing U.S. export control laws, companies turn to Christopher Stagg as their go-to counsel to provide practical and strategic advice. In addition to advising clients on all aspects of export controls, he is often engaged as the lawyer of “last resort” for enforcement defense and to reverse adverse government actions, and he has the rare distinction of litigating export control issues in federal court. He also currently serves as the co-chair of the American Bar Association’s export controls and economic sanctions committee.

Some of his representative experiences include: 

  • Engaged by a Fortune 150 company to replace its long-standing outside export controls counsel, representing it in a high-stakes matter before the Directorate of Defense Trade Controls that was readily resolved with a novel legal argument.  
  • Litigated constitutional and regulatory interpretative issues concerning the ITAR, leading to a federal appellate court finding one of the agency’s core regulatory interpretations as meritless, a rare appellate success against the agency.
  • Advised numerous publicly traded companies on complying with ITAR consent agreements, including by leading the jurisdiction and classification review requirement and developing enterprise-wide policies and procedures. 
  • Successfully represented scores of companies in commodity jurisdiction and commodity classification requests, including appeals, as well as in obtaining favorable regulatory interpretations through advisory opinion requests. 
  • Successfully advocated numerous revisions to the ITAR and Export Administration Regulations that advance and protect the clients’ interests, as well as by receiving favorable statutory and regulatory interpretations.

Christopher brings special insight into export controls and national security issues by drawing on his substantial experience within government as a senior advisor at the Department of State’s Directorate of Defense Trade Controls (DDTC). At DDTC, he was deeply involved as the deputy lead in rewriting the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), including by revising the U.S. Munitions List and Commerce Control List. He also drastically reformed the ITAR’s commodity jurisdiction procedure, where he was involved in hundreds of cases, and advised the Federal Bureau of Investigation on export enforcement investigations. 

Mr. Stagg has been featured or quoted by many leading publications on export control matters, including by the Wall Street Journal, Law360, Bloomberg, Global Investigations Review, Export Compliance Daily, WorldECR, and Export Compliance Manager. He has been a speaker at prominent industry events, such as by the American Bar Association, Society for International Affairs, Kuhne + Nagel, and American Conference Institute. He also served for 10 years as the co-editor of the American Bar Association’s Year-in-Review for export controls and economic sanctions.

In addition to his government experience, Christopher was an export controls and national security attorney at two distinguished Washington, D.C. laws firms, and he had his own previous award-winning law firm that was “highly commended” by WorldECR.

Private Experience

  • Successfully defended U.S. and non-U.S. companies in ITAR and EAR enforcement cases, counseling them on potential defenses, developing the legal strategy, anticipating government concerns, and advising on corrective actions.
  • Engaged by a Fortune 150 company to replace its long-standing outside export controls counsel, representing it in a high stakes matter before the Directorate of Defense Trade Controls that was readily resolved with a novel legal argument.
  • Litigated constitutional and regulatory interpretative issues concerning the ITAR, leading to a federal appellate court finding one of the agency’s core regulatory interpretations as meritless, a rare appellate success against the agency.
  • Originated a novel legal argument, later successfully used by state attorney generals in federal litigation, that removing a specific article from the U.S. Munitions List without Congressional notification violates the Arms Export Control Act (AECA).
  • Through authoritative legal guidance, conducted exhaustive jurisdiction and classification assessments involving the most complex items and situations, including encryption products, software, technical data, and services.
  • Successfully represented scores of companies in commodity jurisdiction and commodity classification requests, including appeals, as well as in obtaining favorable regulatory interpretations through advisory opinion requests.
  • Advised numerous publicly traded companies on complying with ITAR consent agreements, including by leading the jurisdiction and classification review requirement and developing effective policies and procedures.
  • Successfully advocated numerous revisions to the ITAR and Export Administration Regulations that advance and protect the clients’ interests, as well as by receiving favorable statutory and regulatory interpretations.
  • Advised many companies, including defense primes, on designing and implementing effective policies and procedures to conduct high-confidence jurisdiction and classification assessments.
  • Successfully obtained the reinstatement of a debarred party under the ITAR and AECA.
  • Lead audits and internal investigations concerning potential violations of the ITAR and EAR, including advising on decisions whether to submit voluntary disclosures, and advising on corrective actions, gap analysis, and mitigation.
  • Successfully obtained CFIUS clearance for multiple transactions involving U.S. critical technology companies. Counsel companies on CFIUS applicability and related risks, including whether critical technologies are involved.
  • Counseled companies on identifying the applicability and related risks of CFIUS, including preparing related CFIUS filings and determining whether critical technologies are involved.
  • Advised non-U.S. companies on application of the EAR’s de minimis and foreign direct product rules to provide authoritative guidance whether foreign made items are subject to the EAR.
  • Advised a Fortune Global 150 company and its senior executive management team on rapidly changing economic sanctions developments concerning Countering America’s Adversaries Through Sanctions Act (CAATSA) and related regulatory changes by OFAC.
  • Served as lead outside counsel to assist a telecommunications company on establishing ongoing civilian communications services in an embargoed country in compliance with U.S. export controls and economic sanctions laws.

Government Experience

  • Deputy lead for the Directorate of Defense Trade Controls on Export Control Reform and served as a member on interagency policy subcommittees chaired by the National Security Council staff.
  • Revised the U.S. Munitions List and Commerce Control List, as well as key regulations within the International Traffic in Arms Regulations and Export Administration Regulations. Authored the new U.S. policy for designating and determining items on the U.S. Munitions List.
  • Substantially reformed the ITAR’s commodity jurisdiction process, the most significant such effort in history, by directly revising the government’s analysis and review procedures for commodity jurisdiction determinations.
  • Held a leadership position within the commodity jurisdiction section that determines whether an item is controlled on the U.S. Munitions List. Decided 500+ cases and acted as the lead analyst on high profile, highly controversial matters involving emerging technologies and software
  • Authored advisory opinions to companies, individuals, and foreign governments on ITAR interpretations. Chaired interagency meetings with private companies, other U.S. Government agencies, and foreign governments to address regulatory and international trade issues.
  • Principal ITAR advisor to the Federal Bureau of Investigation (FBI) on export controls and national security investigations. Implemented new methods under National Security Presidential Directive 56 to advise the intelligence and law enforcement community on export violations.
  • Represented the United States in bilateral discussions with Canada on defense trade issues in Ottawa and on Export Control Reform at its Embassy in Washington. Also represented the United States in defense trade discussions with the United Kingdom, France, Israel, and NATO.
  • Authored “Latest NDAA Indicates Several Export Control Statutory and Policy Changes,” WorldECR, November 2023.
  • Contributed to “A Decade of ECR,” Export Compliance Manager, October 2023.
  • Authored “ITAR Jurisdiction and Classification of USML Items,” Bloomberg Law, July 2023.
  • Authored “Trade Compliance Flash: Notable Observations from the Latest ITAR Consent Agreement,” June 6, 2023.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2023.
  • Authored “Looking Forward: Anticipated ITAR Developments in 2023,” January 10, 2023.
  • Authored “DDTC Provides Latest ITAR Enforcement and Regulatory Updates,” June 1, 2023.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2022.
  • Authored “Latest ITAR Consent Agreement Reveals Key Enforcement Trends and Practical Considerations for Industry,” February 2, 2022.
  • Authored “Looking Forward: Anticipated ITAR Developments in 2022,” January 7, 2022.
  • Authored “Lessons for Exporters from DDTC’s ITAR Consent Agreement with Keysight Technologies,” August 18, 2021.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2021.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2020.
  • Authored “D.C. Circuit Clarifies ITAR Criminal Intent Requirement,” August 2019.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2019.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2018.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2017.
  • Authored “Next Steps for Export Control Reform: Options for the Trump Administration,” Nov. 2016.
  • Authored “DDTC Issues Conflicting Guidance Concerning Firearms and Congressional Notification,” Nov. 2016.
  • Authored, “Export Control Reform – Progress Made,” WorldECR, May 2016.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2016.
  • Authored “The ITAR’s “Directly Related” Qualifier – The Importance of Defining the Term,” Sept. 2, 2015.
  • Authored “DDTC’s Arms Export Control Act Problem (In re: ITAR Proposed Rule on Prior Approval for Public Domain Information),” June 16, 2015.
  • Authored “Toolkit for Writing Public Comments on Export Control Reform,” May 4, 2015.
  • Authored “DDTC Advances Proposed Rule for Cloud Computing, Defense Services, Technical Data, Public Domain, and Product of Fundamental Research,” April 30, 2015.
  • Authored “Status Update on Export Control Reform,” April 22, 2015.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2015.
  • Authored “Court Case Reveals Insights into the Commodity Jurisdiction Procedure,” March 16, 2015.
  • Authored “DDTC Requests Public Comments on USML Categories VIII and XIX: Practical Tips for Preparing Effective Comments,” March 2, 2015.
  • Authored “The Curious Case of Technical Data as a Defense Article – And Potential Consequences for Cloud Computing,” Feb. 19, 2015.
  • Authored “The Strategic Commodity Jurisdiction (CJ) Request,” Feb. 16, 2015.
  • Authored “DDTC Issues Overly Expansive Interpretation of the ITAR for Defense Services (and Presumably Technical Data),” Dec. 8, 2014.
  • Authored “Influencing Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules,” Dec. 1, 2014.
  • Co-Editor, Export Controls and Economic Sanctions: Year-in-Review, American Bar Association, Spring 2014.
  • Authored “Export Control Reform: A Review And Look Ahead” for LexisNexis Law360, Dec. 19, 2013.
  • Quoted for Export Control Reform by Bloomberg BNA in “Final Rules Now Effective Revising Controls For Items Related to Aircraft, Turbine Engines,” Oct. 15, 2013
  • Presented on “Civil and Commercial Exports Under the U.S. Export Administration Regulations” at Kuhne + Nagel’s export compliance webinar series on July 25, 2023.
  • Presented on “Review of Proficiency Assignment and Q&A” at the American Conference Institute’s “Passport to Efficiency on the ITAR” on February 23, 2023.
  • Presented on “ITAR Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on February 16, 2023.
  • Presented on “The ‘How To’ of ITAR Classification” at the American Conference Institute’s “Passport to Efficiency on the ITAR” on February 2, 2023.
  • Presented on “Navigating U.S. Export Controls: Jurisdiction and Classification Assessments” for Kuhne + Nagel’s export compliance webinar series on October 12, 2022.
  • Presented on “Demystifying the International Traffic in Arms Regulations” for Kuhne + Nagel’s export compliance webinar series on June 14, 2022.
  • Presented on “ITAR Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on March 4, 2022.
  • Presented on “The ‘How To’ of ITAR Classification” at the American Conference Institute’s “Passport to Efficiency on the ITAR” on February 4, 2022.
  • Presented on “Recent and Anticipated Trends in ITAR and Exports Controls Enforcement” on February 2, 2022.
  • Presented on “Jurisdiction and Classification Assessments: Navigating High-Risk ITAR and Export Control Situations” on November 10, 2021.
  • Presented on “Lessons for Exporters from Keysight Technologies and Other DDTC ITAR Consent Agreements” on September 1, 2021.
  • Presented on “The ‘How To’ of ITAR Classification” at the American Conference Institute’s “Passport to Efficiency on the ITAR” on April 8, 2021.
  • Presented on “ITAR Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on February 26, 2021.
  • Presented on “Handling Voluntary Disclosures and Internal Investigations” for the Export Compliance Training Institute on February 26, 2019.
  • Presented at the Export Compliance Training Institute’s ITAR Defense Trade Controls Seminar on November 12, 2018, in Alexandria, VA.
  • Presented on “Jurisdiction and Classification: Handling CJs, CCATS, Self-Determinations, and Creating JCA Systems” for the Export Compliance Training Institute on May 2, 2018.
  • Presented on “Export Control Reform Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on February 28, 2018.
  • Presented on “Export Control Reform Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on February 7, 2017.
  • Presented on “Export Controls: The Impact of ITAR Regulations to Your Industry & Your Business” at The Knowledge Group’s webinar on January 11, 2017.
  • Presented on “Export Control Reform and Compliance Strategies: Latest Developments in Export Controls” at The Knowledge Group’s webinar on July 15, 2016.
  • Presented on “The Art of the Voluntary Disclosure and Internal Investigation” for the Export Compliance Training Institute on May 4, 2016.
  • Presented on “Significant Amendments to the International Traffic In Arms Regulations (ITAR)” at The Knowledge Group’s webinar on March 1, 2016.
  • Presented on “Export Control Laws: Practice and Procedure” at the New York City Bar Association in New York, NY on February 9, 2016.
  • Presented on “Export Control Reform Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on January 28, 2016.
  • Presented on “Jurisdiction and Classification: Handling CJs, CCATS, and Self-Determinations” for the Export Compliance Training Institute on October 28, 2015.
  • Presented on “ITAR and EAR Harmonization Rule – Preparing Comments” with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce, Edward Peartree of the U.S. Department of State and Jahna Hartwig of Sikorsky Aircraft Corporation for the American Bar Association (ABA) on July 21, 2015 in Washington, D.C.
  • Presented on “Responding to the State Department’s Proposed ITAR Prior Approval Requirement for Public Domain Information,” in Washington, D.C. on July 8, 2015.
  • Presented on “Export Controls: Administrative Law and Rulemaking,” at the Impact of Export Controls on Higher Education & Scientific Institutions conference in Washington, D.C. on June 9, 2015.
  • Presented with Asst. Secretary Kevin Wolf of the U.S. Department of Commerce on “Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules,” in Washington, D.C. on February 25, 2015.
  • Presented on “ITAR to EAR: Mastering the Complexity and Maximizing the Benefits of the New Reform Rules” at The Knowledge Group’s webinar on February 9, 2015.
  • Presented on “Export Control Reform” and “ITAR Developments” at the American Bar Association’s Year-in-Review Session in Washington, D.C. on January 22, 2015.
  • Presented at NAITA’s Export Control Roundtable on “Jurisdiction and Classification: State or Commerce? Has My Jurisdiction Changed as a Result of Export Control Reform?” in Huntsville, Alabama on December 4, 2014.
  • Presented on “Export Control Reform” with Todd Willis of the U.S. Department of Commerce at SRA International’s Managing the Legal & Regulatory Research Landscape Conference in Washington, D.C. on June 19, 2014.
  • Presented on “Reclassifications of Controlled Goods: Incorporating US Export Control Reform, the Wassenaar Arrangement and EU Export Control Reforms into Your Approach” at C5’s 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014.
  • Presented on “US Export Control Reform Update: How to Prioritise your Compliance Approach to Operate under the EAR and Handle the Latest Reforms”at C5’s 8th Advanced Forum on Export Controls in Brussels, Belgium on May 20, 2014.
  • Presented on “Export Controls and Space Research” at the Second Annual Impact of Export Controls on Higher Education and Scientific Institutions conference in Atlanta, GA on May 6, 2014.
  • Presented on “Classification Post Export Control Reform” at the Society of International Affairs Conference on Export Control Reform in New Orleans, LA on May 5, 2014.
  • Presented at the Embassy of Canada on “Export Control Reform: New Approaches and Opportunities for the Satellite Industry” in Washington, D.C. on March 12, 2014.
  • Presented at the American Bar Association’s CLE on export controls and economic sanctions in Washington, D.C. on January 22, 2014.
  • Presented on “Advanced ITAR Issues: Practical Strategies For Managing Export Control Reform” in Washington, D.C., Dec. 17, 2013.
  • Presented at the December meeting of the New York City Bar Association’s International Trade Committee on “Export Controls, Economic Espionage, and National Security” in New York, NY, Dec. 3, 2013.
  • Presented at the National Academies’ Government-University-Industry Research Roundtable in Washington, D.C. on “Understanding Research Globalization in the Context of National Security and Prosperity,” Oct. 22, 2013.
  • Presented at the Embassy of France in Washington, D.C. on “Export Control Reform,” Oct. 11, 2013.
  • Presented at the Embassy of France in Washington, D.C. to “An Overview of U.S. Export Control Laws,” Sept. 26, 2013.
  • Presenter, “Addressing Classification and Jurisdictional Determinations,” ITAR Summit, Momentum Events, June 2013.
  • Guest Lecturer, “The Lachmann Case and Specially Designed: Applications of Constitutional Law to Export Controls,” Georgetown University Law Center, June 2013.
  • Presenter, “Update on Export Control Reform,” Private Conference, May 2013.
  • Presenter, “Overview of the Commodity Jurisdiction Procedure,” U.S. Department of State In-House Training, March 2013.
  • Presenter, “Export Control Reform: An Update and Primer,” ITAR Compliance Conference, Marcus Evans, Feb. 2013.
  • Presenter, “Commodity Jurisdiction: Practical Tips and Considerations,” Private Conference, Sept. 2012.