Polsinelli’s cross-departmental team of international trade attorneys are experienced at navigating the complicated web of regulations overseen by several federal agencies that apply to exports of U.S. origin products and technology. Polsinelli attorneys assist U.S. firms, their foreign trading partners, and transportation and cargo carriers with navigating through and beyond this complex and ever-evolving regulatory environment to achieve compliance with U.S. export controls. Whether you need a one-time license, a comprehensive export program, or are seeking information on possible restrictions to exporting your product or service, Polsinelli can help.

  • Export control services include advice and counsel on the requirements of the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), Foreign Assets Control Regulations (FACR), and the Foreign Trade Regulations.
  • The firm assists clients in determining the proper commodity jurisdiction of their products, software and technology/technical data, as well as their classifications under the Commerce Control List, U.S. Munitions List and Schedule B Code.
  • Polsinelli’s attorneys determine the applicable export and reexport licensing requirements for companies’ products and technology/technical data, assess whether any license exceptions or exemptions or available, and assist companies in obtaining the requisite government authorizations.
  • Polsinelli assists companies in ensuring that their proposed shipments and technology transfers are subject to effective end-use, diversion risk (“red flag”), restricted parties list, and embargoed country screening protocols, and works with them to establish and rollout effective screening mechanisms.
  • The firm works with companies to navigate the often complex embargo and economic sanctions programs of the United States and other countries in which they do business.
  • Polsinelli conducts internal technology reviews for companies and provides guidance in issues relating to deemed exports and transfers of technical data to foreign national employees.
  • The firm assists clients in ensuring proper export clearance and Automated Export System (AES) compliance, as well as analyzes their AES data in order to assess compliance risks, evaluate third party service provider compliance levels, and identify additional cost-saving opportunities.
  • Polsinelli’s attorneys advise companies on the export and customs clearance requirements of non-US jurisdictions.
  • The firm also counsels companies on the intricate U.S. antiboycott regulations, and assists in the timely submission of reportable foreign boycott-related requests to the Office of Antiboycott Compliance.
  • Polsinelli routinely provides in-house export compliance training, conducts internal export compliance assessments, and assists companies in the preparation and submission of voluntary disclosures, when warranted.
  • Polsinelli assesses target companies’ potential import and export liability as part of due diligence investigations in proposed mergers, acquisitions & divestitures.
  • Polsinelli attorneys help clients prepare and submit voluntary disclosures of violations to the relevant government agencies, navigate enforcement actions, and work to obtain the most favorable possible result.
  • The firm represents clients through all stages of export enforcement actions, including detentions, seizures, forfeitures, administrative subpoenas and penalty cases.
Related Capabilities
Publications
IEEPA Refund Portal Opens on April 20: What Importers Should Know About Filing, Timing and Liquidity Options
Key Takeaways U.S. Customs and Border Protection (CBP) will launch Phase 1 of CAPE on April 20, giving many importers their first access to the ACE-based path to request IEEPA duty refunds. More complicated entries – including those involving certain AD/CVD orders, protests, drawback, reconciliation and liquidated entries that are more than 80 days past liquidation – remain outside Phase 1 or will follow a different timeline. Importers and brokers should act now to confirm ACE portal access, ACH/electronic refund enrollment, U.S. bank account information and entry eligibility before submitting CAPE declarations. CBP also has made clear that filers may not initiate an IEEPA refund request through a Post Summary Correction (PSC). Timing of refund declaration processing will vary. For many standard accepted entries, CBP
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CBP to Launch Phase One of CAPE for IEEPA Refunds on April 20
Key Takeaways U.S. Customs and Border Protection (CBP) will launch the first phase of its Consolidated Administration and Processing of Entries (CAPE) tool to process International Emergency Economic Powers Act (IEEPA) duty refunds on April 20. Phase one is limited to most unliquidated entries and entries within 80 days of liquidation, while more complex scenarios will be addressed in later phases as more functionality is added to the CAPE system. Importers and brokers should prepare now by confirming ACE Portal access, ensuring that their U.S. bank account information is accurate and up to date, and identifying entries eligible for phase one processing.  On April 10, 2026, CBP issued Cargo Systems Messaging Service Number 68315804, announcing that the first phase of CAPE will go live
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