Larry Christensen concentrates on export controls, sanctions, and embargoes under the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and various regulations issued by the Office of Foreign Assets Control (OFAC).
He focuses on the pre-acquisition due diligence, Committee on Foreign Investment in the United States (CFIUS) reviews of foreign direct investment, and the defense of enforcement cases, as well as compliance processes, assessments, and audits.
Mr. Christensen counsels firms on the development of compliance strategies, process assessments and audits, and assists firms facing governmental administrative audits and criminal investigations. He has advised corporations on the most challenging substantive areas of export controls, such as commodity jurisdiction, the outer limits of U.S. re-export rules, encryption, and OFAC restrictions on facilitation.
Mr. Christensen served in the U.S. Department of Commerce for 11 years in the Office of Chief Counsel of Export Administration and as Director of the Regulatory Policy Division. In that role, he headed the complete redrafting of the EAR from 1995 to 1996, the first such rewrite since 1949. He also authored the deemed export rule and coordinated the policy support for the rule prior to its publication. He drafted all Export Administration Act proposed legislation for the Reagan, George H.W. Bush, and first Clinton administrations.
Since 1979, he has counseled clients on ITAR. During his years at Commerce, Mr. Christensen was primarily responsible for the regulatory and interagency issues surrounding the State Department scope of jurisdiction under the ITAR and, on behalf of Commerce, negotiated with the State Department on the current standards for commodity jurisdiction under the ITAR. While Vice President of Export Controls for JPMorgan Chase Vastera from 1997 to 2007, he trained and supervised consultants and managed services employees that performed more than 10,000 self-determinations, more than 80,000 classifications, and more than 100 export compliance assessments.Back