Alexandra Baj

Alexandra Baj

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues.  Ms. Baj advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), US sanctions regulations administered by the Office of Foreign Assets Control (OFAC), and nuclear export controls under the jurisdiction of the Nuclear Regulatory Commission (NRC).  Alex specializes in the development and implementation of export and anti-corruption compliance policies and procedures and training, internal investigations and voluntary disclosures under the EAR, the ITAR, and OFAC rules, due diligence for mergers and acquisitions, and on encryption and cybersecurity export controls.  Her clients include companies involved in defense, aerospace, software, semiconductor, and uranium processing industries.

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BIS Again Extends ZTE Temporary General License

On February 24, 2017, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) is publishing in the Federal Register a notice again extending its temporary general license for exports, reexports, and in country transfers to Zhongxing Telecommunications Equipment (ZTE) Corporation (ZTE Corporation) and ZTE Kangxun.  BIS is extending the period of the license … Continue Reading

OFAC Issues General License Authorizing Certain Dealings with FSB Related to Encryption Import Licensing

The US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a General License today authorizing certain transactions with the Russian Federal Security Service (known as “FSB”) related to seeking licenses, notifications, and other authorizations with the FSB for the importation, distribution, or use of information technology products in the Russian Federation.  The General License … Continue Reading

Significant Update to US Encryption Export Rules (and Other Commerce Control List Changes)

On September 20, the US Department of Commerce (DOC) published a final rule revising the Commerce Control List (CCL) and other sections of the Export Administration Regulations (EAR).  This rule implements revisions decided at the December 2015 Wassenaar Arrangement plenary meeting, but also includes additional updates to the EAR.  The final rule revises 58 Export … Continue Reading

BIS Extends ZTE Temporary General License

On August 19, 2016 the Commerce Department Bureau of Industry and Security (BIS) is publishing in the Federal Register a notice extending its temporary general license for exports, reexports, and in country transfers to Zhongxing Telecommunications Equipment (ZTE) Corporation (ZTE Corporation) and ZTE Kangxun.  BIS is extending the period of the license from its current … Continue Reading

Proposed Cybersecurity Export Rule

On May 20, 2015, the US Department of Commerce’s Bureau of Industry and Security (BIS) published a proposed export control rule that seeks to impose strict controls on the export of certain intrusion and surveillance (“cybersecurity”) items.  The rule would add new licensing and reporting requirements for companies developing and exporting intrusion and surveillance cyber … Continue Reading
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