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
Tariff Heat Wave: Importers Face New Section 301 Proposals, Section 232 Risk and Heightened Customs Enforcement
The summer tariff landscape is developing quickly. As Section 122 duties approach their July 24, 2026 expiration, the Administration is advancing alternative mechanisms to preserve, replace or supplement the current duty structure. For businesses, the central issue is no longer whether a single tariff applies, but how multiple tariff programs could overlap. Several recent proposals contemplate duties that would apply in addition to other applicable duties unless an exemption applies. In this report, we review 10 key tariff and trade developments shaping tariff exposure, supply-chain planning and customs compliance, and offer practical steps importers should consider now to assess cumulative duty exposure and prepare for potential changes. Read the Report
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U.S. Court of International Trade Invalidates Trump Section 122 Global Tariffs, the Administration Appeals, and Tariffs Likely Will Remain in Effect for Most Importers
Key Takeaways The U.S. Court of International Trade (CIT) invalidated President Trump’s Section 122 10% tariffs, holding that the Administration exceeded the authority delegated by Congress under Section 122 of the Trade Act of 1974. The Administration has appealed the decision to the U.S. Court of Appeals for the Federal Circuit. The CIT’s injunction is limited. The court granted relief only to the plaintiffs – the State of Washington, Burlap & Barrel and Basic Fun! – and declined to issue nationwide relief. The tariffs remain in place for most importers pending appeal, and continue to apply broadly unless additional importers seek and obtain relief. The decision increases pressure on the Administration to pivot to alternative statutory authorities, including Section 301 and Section 232, for
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