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. In addition, he has substantial technical and classification experience in industries such as seismic, oil and gas, aerospace, night vision, navigation, special metals, information technology, telecommunications, machine tools, sensing devices, accelerometers, chemicals, and bio toxins. He has experience in technology transfer in avionics, gas turbine engines, missile development, telecommunications, computers, and chemicals.
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. Since leaving Commerce in 1997, Mr. Christensen has dedicated more than half of his time to ITAR matters. 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.
Mr. Christensen is the author of the EAR provisions regarding publicly available treatment, including the provisions regarding the scope of the academic exclusion under EAR. He co-authored the “Know Your Customer” Guidance and “Red Flags Under the EAR.” In addition, he led the U.S. delegation at the Coordinating Committee for Multilateral Export Controls in connection with the drafting of the General Technology Note. In multilateral control negotiations, he represented the U.S. in China and at the multilateral national security regime.
Mr. Christensen is familiar with the export laws of many countries. He served on the team that trained the Government of Singapore before it implemented its export control laws. He has testified before the U.S. Senate and House of Representatives regarding export control legislative developments.
He trains on all U.S. export control and sanctions topics and has lectured on export controls in China, Brazil, Argentina, Singapore, Finland, Germany, the United Kingdom, and the United States. He is a frequent speaker for the Practicing Law Institute and the American Conference Institute. Mr. Christensen was also a speaker during the China seminars sponsored by the U.S. Department of Commerce. < Brief Bio