Kevin J. Wolf

Key Experience

• Has more than 25 years’ experience providing advice and counseling regarding the laws, regulations, policies, practices and politics pertaining to export controls, sanctions, national security reviews of foreign direct investments and other international trade issues.
• Has deep experience that includes being a Special Compliance Officer, civil and criminal defense, internal investigations, due diligence audits and compliance program enhancements.
• Served as Assistant Secretary of Commerce for Export Administration, Bureau of Industry and Security

Practice

Kevin Wolf’s practice focuses on the:

• Export Administration Regulations (EAR)
• International Traffic in Arms Regulations (ITAR)
• Regulations administered by the Committee on Foreign Investment in the United States (CFIUS)
• U.S. international trade policies
• Regulations administered by the Office of Foreign Assets Control (OFAC).

In his role at the Commerce Department, Kevin’s primary responsibilities included:

• Developing and implementing policies pertaining to administration of U.S. export controls, particularly the licensing requirements of the EAR
• Representing the Commerce Department in meetings of CFIUS
• Developing and implementing, with Obama administration leadership and career staff, the Export Control Reform (ECR) initiative, which primarily pertained to revising the structure of defense trade controls.

Representative Work

• Is the Special Compliance Officer for the U.S. State Department to monitor a multinational company’s compliance with the ITAR and requirements of a consent agreement.
• Advises U.S. semiconductor and other high technology companies regarding compliance with the Export Administration Regulations (EAR), including the prohibitions pertaining to activities involving foreign companies on the EAR’s Entity List, Denied Persons List and Unverified List.
• Advises U.S. space, launch and aircraft companies regarding complex jurisdictional, classification, interpretation and licensing issues associated with the controls of the ITAR and the EAR.
• Prepares draft comments for companies and trade associations in response to requests from the departments of State and Commerce regarding emerging and foundational technologies, the lists of dual-use and military items, and U.S. critical infrastructure.
• Provides advice to companies regarding the applicability of Treasury Department’s CFIUS regulations to transactions and business plans, particularly with respect to matters involving “critical technologies.”
• Provides day-to-day advice and formal opinions in most technology sectors regarding complex export control jurisdiction, classification, interpretation and licensing matters.
• Defends individuals and corporations under investigation for civil and criminal violations of export control and sanctions regulations.
• Leads company-wide export control, sanctions and foreign direct investment compliance program reviews, enhancements and due diligence efforts.
• Conducts extensive training for companies in multiple industries regarding the scope, meaning and application of U.S. export control and sanctions laws and regulations.
• Conducts internal export control compliance investigations and, as warranted, the preparation of voluntary disclosures and related corrective action measures.