Christopher Stagg solves complex and high-stakes export control challenges by uniquely integrating three critical perspectives into a unified strategy: former export controls regulator, export controls litigator, and export controls enforcement defense attorney.

Christopher shaped export control laws from inside government. As an export controls regulator, he was an architect of the current regulatory framework. He was a senior advisor at the U.S. Department of State's Directorate of Defense Trade Controls (DDTC) and the deputy lead for Export Control Reform. In that role, he made significant changes to the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), including to the entire U.S. Munitions List. He also authored the U.S. policy for determining which items belong on the U.S. Munitions List, authoritatively interpreted the ITAR, and substantially reformed the interagency commodity jurisdiction procedure. In addition, he advised on hundreds of civil and criminal investigations.

Christopher has also shaped export control laws from outside government. He has rare export control litigation experience that includes securing the only U.S. Court of Appeals decision to reject DDTC's interpretation of the ITAR – a unanimous decision – along with district court rulings that the government did not appeal. In that litigation, the government also conceded that First Amendment strict scrutiny applies to the ITAR's technical data controls, and the government abandoned a related rulemaking. Additionally, he originated a novel legal argument that 19 state attorneys general used to successfully challenge the ITAR's statutory authority, a decision the government likewise did not appeal.

Christopher’s advocacy before the regulatory agencies has produced similarly significant results. For example, he led the defense of a contested proposed charging letter, resulting in one of the most favorable settlements in ITAR enforcement history. He has secured no-penalty resolutions in egregious cases and advised six companies on navigating their consent agreements to secure closure. He has also led a consent agreement jurisdiction and classification review under intense government scrutiny, with the regulators approving his methodology without changes. His rulemaking advocacy has led to significant regulatory changes and the government abandoning proposed rules.

Beyond shaping the law, Christopher pioneered the multidisciplinary, high-stakes export control practice that is now widely seen across major law firms. He was previously a partner at an AmLaw 50 firm, where he led this practice and founded its ITAR & Defense Trade Compliance group.

Christopher contributes to the field through bar leadership, scholarship, and public commentary. He co-chairs the American Bar Association's export controls and economic sanctions committee and is a fellow of the American Bar Foundation. He is also a contributing author to the leading treatise United States Export Controls (Law Journal Press). He frequently speaks at events such as the Society for International Affairs and the American Conference Institute. He is featured or quoted in leading publications, including The Wall Street Journal and Bloomberg, and has been profiled by Export Compliance Manager and The Export Practitioner, which describes him as a "trailblazing attorney."

Before his legal career, Christopher was a reporter for Jane’s Defence Weekly and a military analyst at the strategic advisory section of Jane’s Information Group.

Representative Experience

  • Led the defense of a proposed charging letter involving disputed ITAR violations, resulting in the longest-known contested proposed charging letter and one of the most favorable settlements in ITAR enforcement history.
  • Litigated constitutional and regulatory interpretive issues concerning the ITAR, leading to a federal appellate court finding the agency’s regulatory interpretation meritless, the only appellate decision to invalidate the agency’s construction of the regulations.
  • Led the pre-litigation strategy for a Fortune 500 subsidiary that identified several novel constitutional and statutory issues with U.S. export control laws, with the strategy ultimately leading to resolution without any litigation.
  • Engaged by a Fortune 500 company to resolve an urgent matter before DDTC involving the potential shutdown of critical aerospace programs due to pending regulatory revisions; case was resolved within one week through a novel legal argument agreed to by DDTC.
  • Provided proactive defense counsel to companies on understanding and complying with the EAR's semiconductor, supercomputer, and encryption rules, including the de minimis and foreign direct product rules.
  • Led the jurisdiction and classification review for a publicly traded company under an ITAR consent agreement, including developing the review methodology—which DDTC approved without any changes.
  • Served as review counsel to trial defense teams in export control criminal matters involving the ITAR and EAR, identifying and developing additional legal arguments that included never-before-raised export control arguments.
  • Sought out by a company under an ITAR consent agreement to lead a sensitive voluntary disclosure that was successfully resolved within one week of filing and without further action by DDTC.
  • Brought in as special counsel to reverse a commodity jurisdiction ruling concerning sophisticated military software, leading to a successful appeal and a resulting EAR99 determination.
  • Defended a non-U.S. multinational company from alleged EAR reexport and retransfer violations of military and civilian goods, leading to successful resolution without penalty.
  • Advised a Fortune 500 company on the strategy for a high-stakes ITAR disclosure where there was substantial risk of receiving a proposed charging letter and consent agreement; the matter was successfully resolved without penalty.
  • Engaged by a Fortune 500 company to guide it through its commodity jurisdiction requests, directing the strategy and advocacy that led to scores of favorable determinations.
  • Defended a non-U.S. company in a far-reaching export control investigation involving alleged unauthorized re-exports under the EAR and across multiple BIS subpoenas.
  • Obtained the reinstatement of a U.S. company that was statutorily debarred under the Arms Export Control Act and ITAR following a criminal conviction; the petition's written advocacy alone satisfied DDTC's concerns, and reinstatement was readily granted.
  • Resolved a Fortune 500 company's disagreements with DDTC and its special compliance officer under an ITAR consent agreement, and developed effective enterprise-wide policies and procedures to satisfy its consent agreement.
  • Defended a U.S. company in a mandatory ITAR disclosure involving potential unauthorized exports of significant military equipment to China where there was presumed harm to national security; the matter was successfully resolved without penalty.
  • Successfully obtained an EAR99 classification through the commodity classification (CCATS) process for encryption software to resolve a dispute where a third party believed the software was controlled as ECCN 5D002.
  • Advised a Fortune 500 company on a highly complex regulatory interpretation involving an edge case under the ITAR that affected international operations and where no relevant agency guidance exists.
  • Assisted a Fortune 500 aerospace and defense subsidiary under an ITAR consent agreement by enhancing its jurisdiction and classification program to identify and handle complex assessments, including edge cases and the ITAR's see-through rule.
  • Advised a publicly traded company under an ITAR consent agreement on determining the jurisdiction and classification of more than 6,000 items, including ITAR-controlled technical data and EAR-controlled technology.
  • Originated a novel legal argument, later successfully used by 19 state attorneys general in federal litigation, that removing a specific article from the U.S. Munitions List without congressional notification violates the ITAR's enabling statute, the Arms Export Control Act.

Selected Presentations

  • Moderator, “EAR Enforcement – Key Decisions and Trends,” American Bar Association, Washington, D.C., June 24, 2026.
  • Presenter, “ITAR Regulatory Developments,” American Bar Association’s Year-in-Review, Washington, D.C., June 17, 2026.
  • Presenter, “ITAR Developments: What's on the Horizon for 2026 and Beyond,” Advanced Forum on Global Export Controls, American Conference Institute, Arlington, VA, Feb. 24, 2026.
  • Presenter, “The Future of Export Enforcement Defense,” Holland & Knight Webinar, Nov. 5, 2025.
  • Presenter, “ITAR Priorities & Industry Discussion,” Society for International Affairs Spring Advanced Virtual Conference, May 19, 2025.
  • Presenter, “Hot Topics in ITAR Enforcement & Compliance,” Holland & Knight Webinar, April 29, 2025.
  • Presenter, “Unpacking ITAR Compliance to Make the U.S. Defense Industrial Base Stronger,” Apex Defense, Washington, D.C., April 23, 2025.
  • Presenter, “The Changing Impact of Voluntary Disclosures on Settlement and Penalty Outcomes,” Advanced Forum on Global Export Controls, American Conference Institute, Arlington, VA, Feb. 25, 2025.
  • Presenter, “Navigating High-Risk Export Control Situations with High Confidence,” 15th Annual Export Expo, Massachusetts Export Center, Jan. 30, 2025.
  • Presenter, “Jurisdiction and Classification: Handling Complex ITAR and Export Control Assessments,” International Compliance Professionals Association, Feb. 20, 2024.
  • Presenter, “Influencing Export Controls: Preparing Effective Public Comments to ITAR and EAR Rulemaking,” Massachusetts Export Center's Export Expo, Jan. 25, 2024.
  • Presenter, “U.S. Export Enforcement: Best Practices for Preventing and Responding to Violations,” Kuehne + Nagel Webinar, Dec. 13, 2023.
  • Presenter, “Ten-Year Anniversary of Export Control Reform,” National Council on International Trade Development, Washington, D.C., Oct. 11, 2023.
  • Presenter, “Demystifying the International Traffic in Arms Regulations,” Kuehne + Nagel Webinar, June 14, 2022.
  • Presenter, “Recent and Anticipated Trends in ITAR and Export Controls Enforcement,” Miller & Chevalier Webinar, Feb. 2, 2022.
  • Presenter, “Handling Voluntary Disclosures and Internal Investigations,” Export Compliance Training Institute, Feb. 26, 2019.
  • Presenter, “Export Control Reform Developments,” American Bar Association's Year-in-Review Session, Washington, D.C., Feb. 28, 2018.
  • Presenter, “Export Controls: The Impact of ITAR Regulations to Your Industry & Your Business,” The Knowledge Group, Jan. 11, 2017.
  • Presenter, “The Art of the Voluntary Disclosure and Internal Investigation,” Export Compliance Training Institute, May 4, 2016.
  • Presenter, “Export Control Laws: Practice and Procedure,” New York City Bar Association, New York, NY, Feb. 9, 2016.
  • Presenter, “ITAR and EAR Harmonization Rule - Preparing Comments,” American Bar Association, Washington, D.C., July 21, 2015.
  • Presenter, “Export Controls: Administrative Law and Rulemaking,” AUECO Conference, Washington, D.C., June 9, 2015.
  • Presenter, “Export Control Reform: Preparing Effective Public Comments for the Next Tranche of Proposed Rules,” Stagg P.C. Webinar, Feb. 25, 2015.
  • Presenter, “Jurisdiction and Classification: State or Commerce? Has My Jurisdiction Changed as a Result of Export Control Reform,” NAITA's Export Control Roundtable, Huntsville, AL, Dec. 4, 2014.
  • Presenter, “U.S. Export Control Reform Update,” C5's 8th Advanced Forum on Export Controls, Brussels, Belgium, May 20, 2014.
  • Presenter, “Export Controls and Space Research,” AUECO Conference, Atlanta, GA, May 6, 2014.
  • Presenter, “Classification Post Export Control Reform,” Society for International Affairs Conference, New Orleans, LA, May 5, 2014.
  • Presenter, “Export Control Reform: New Approaches and Opportunities for the Satellite Industry,” Embassy of Canada, Washington, D.C., March 12, 2014.
  • Presenter, “Understanding Research Globalization in the Context of National Security and Prosperity,” National Academies, Washington, D.C., Oct. 22, 2013.
  • Guest Lecturer, “The Lachmann Case and Specially Designed: Applications of Constitutional Law to Export Controls,” Georgetown University Law Center, Washington, D.C., June 2013.
  • Presenter, “Overview of the Commodity Jurisdiction Procedure,” U.S. Department of State, Washington, D.C., March 2013.

Selected Publications

  • Authored, "DDTC Publishes Latest Regulatory Agenda for the ITAR and U.S. Munitions List," Varick Alert, July 8, 2026.
  • Authored, “Recent ITAR Amendments Expand the U.S. Munitions List and Signal Further Expansion,” Holland & Knight Alert, Sept. 22, 2025.
  • Authored, “Trump Administration Publishes List of Planned ITAR Changes,” Holland & Knight Alert, Sept. 4, 2025.
  • Authored, “A Look at Anticipated ITAR Rulemaking Developments for 2025,” Holland & Knight Alert, Jan. 7, 2025.
  • Authored, “State Department Finalizes ITAR Registration Fee Increases,” Holland & Knight Alert, Dec. 11, 2024.
  • Authored, “DDTC Offers Compliance Suggestions for Brokering and Political Contributions,” Export Compliance Manager, Sept. 2024.
  • Authored, “ITAR Criminal Case Challenges the Constitutionality of Specially Designed,” Stagg PLLC Client Alert, Feb. 16, 2024.
  • Authored, “Congress Mandates More Frequent Reviews of the U.S. Munitions List,” Stagg PLLC Client Alert, Jan. 17, 2024.
  • Authored, “Latest NDAA Indicates Several Export Control Statutory and Policy Changes,” WorldECR, Nov. 2023.
  • Contributor, “A Decade of ECR,” Export Compliance Manager, Oct. 2023.
  • Authored, “ITAR Jurisdiction and Classification of USML Items,” Bloomberg Law, July 2023.
  • Authored, “DDTC Provides Latest ITAR Enforcement and Regulatory Updates,” Miller & Chevalier Trade Compliance Flash, June 1, 2023.
  • Authored, “Looking Forward: Anticipated ITAR Developments in 2023,” Miller & Chevalier Trade Compliance Flash, Jan. 10, 2023.
  • Authored, “Latest ITAR Consent Agreement Reveals Key Enforcement Trends and Practical Considerations for Industry,” Miller & Chevalier Trade Compliance Flash, Feb. 2, 2022.
  • Authored, “Lessons for Exporters from DDTC's ITAR Consent Agreement with Keysight Technologies,” Miller & Chevalier Trade Compliance Flash, Aug. 18, 2021.
  • Authored, “D.C. Circuit Clarifies ITAR Criminal Intent Requirement,” Stagg P.C. Client Alert, Aug. 2019.
  • Authored, “DDTC Issues Conflicting Guidance Concerning Firearms and Congressional Notification,” Stagg P.C. Client Alert, Nov. 2016.
  • Authored, “Export Control Reform – Progress Made,” WorldECR, May 2016.
  • Authored, “DDTC’s Arms Export Control Act Problem (In re: ITAR Proposed Rule on Prior Approval for Public Domain Information),” Stagg P.C. Client Alert, June 16, 2015.
  • Authored, “Toolkit for Writing Public Comments on Export Control Reform,” Stagg P.C. Client Alert, May 4, 2015.
  • Authored, “Court Case Reveals Insights into the Commodity Jurisdiction Procedure,” Stagg P.C. Client Alert, Mar. 16, 2015.
  • Authored, “The Strategic Commodity Jurisdiction Request,” Stagg P.C. Client Alert, Feb. 16, 2015.
  • Authored, “Export Control Reform: A Review and Look Ahead,” Law360, Dec. 19, 2013.

Admissions

  • District of Columbia
  • New York
  • U.S. Court of Appeals, Second Circuit
  • U.S. District Court, Southern District of New York
  • U.S. District Court, District of Columbia

Education

  • J.D., Saint Louis University
  • B.A., George Washington University