Alexandra Baj

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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. Alex 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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Latest Articles

On August 8, 2018, the US State Department announced that it would be imposing new sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).  The new sanctions are in response to a determination by the US government that the Russian government was behind the recent use of a nerve agent in the United Kingdom against two UK citizens.  The CBW Act requires the imposition of…
On April 16, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) imposed a denial order involving Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (ZTE Corporation) and ZTE Kangxun Telecommunications Ltd of Hi-New Shenzhen, China (ZTE Kangxun).  The denial order, effective immediately, restricts ZTE Corporation and ZTE Kangxun from participating in any way in any transaction involving any hardware, software, or technology that is exported / re-exported or to be exported /…
The Bureau of Industry and Security at the US Department of Commerce has updated the information on its website to incorporate changes made to its encryption export rules in September of 2016.  The new information includes a helpful reference guide for Category 5, Part 2 of the Export Administration Regulations, flowcharts, and guidance on license exception ENC and its requirements.  The updated website is found here.  …
On April 19, 2017, a US Department of Commerce (DOC) Bureau of Industry and Security (BIS) rule implementing new documentation requirements for certain US exports or reexports to and from Hong Kong will take effect.  The DOC published the final rule on January 19, 2017.  The new rule emphasizes Hong Kong import and export licensing requirements that affect a variety of goods.  It obligates companies using a DOC license or license exception pursuant to the…
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 from its current expiration date of February 27, 2017 to March 29, 2017.  BIS established the license in a notice
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 follows President Obama’s December 29, 2016 executive order regarding malicious cyber-enabled activities that had placed the FSB on OFAC’s list…
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 Control Classification Numbers (ECCNs), adds two ECCNs, and revises license exception eligibility for seven ECCNs.  The changes center on ECCNs…
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 expiration date of August 30, 2016 to November 28, 2016.  BIS established the license in a notice published on March
On March 8, 2016, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice adding four ZTE entities to the BIS Entity list.  Three of the entities are located in China and one is located in Iran.  The Chinese entities are:  (1) Beijing 8-Star International Co., (2) Zhongxing Telecommunications Equipment (ZTE) Corporation; and (3) ZTE Kangxun Telecommunications Ltd.  The Iranian entity is ZTE Parsian. The Entity List designation for…
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 products.  This proposal is meant to implement the December 2013 cybersecurity additions to the Wassenaar Arrangement, an agreement among 41…