Overview
Alexandra Baj heads Steptoe's International Trade and Regulatory Compliance group. She advises on export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Known for her practical and efficient advice, Alexandra has decades of experience in complex international business issues. She represents clients in many industries, from aerospace and defense to metals and mining, telecommunications, software, energy, and food processing and medical devices.
Alexandra's international compliance practice covers export controls, sanctions, and anti-corruption internal investigations and enforcement matters, regulatory analysis, compliance program development and implementation, licensing, export control jurisdictional and classification analysis, encryption export controls, restricted party export and sanctions advice (including complex Entity List matters and sanctions de-listing), and mergers and acquisitions due diligence.
She has experience advising on export controls under the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), US sanctions regulations administered by the Office of Foreign Assets Control (OFAC) (particularly in the area of Russia/Ukraine-related sanctions), and, in the anti-corruption area, on the Foreign Corrupt Practices Act (FCPA) and other statutes.
Alexandra also counsels clients on trade issues arising out of the US antidumping, countervailing duty, and safeguards statutes, as well as bilateral and multilateral relationships with various US trading partners to the General Agreement on Tariffs and Trade and the World Trade Organization (WTO), and customs matters with US Customs and Border Protection.
Alexandra has experience advising clients regarding personnel and facility security clearance issues for businesses working with classified information pursuant to the National Industrial Security Program (NISP). Alexandra represents clients regarding facility clearance issues in mergers and acquisitions and restructuring and appeals of adverse personnel security clearance determinations.
- District of Columbia
- New York
- J.D., University of Chicago Law School, 1999, with honors
- B.A., Kenyon College, 1992, magna cum laude
Areas of Work
Representative Matters
- Represented a telecommunications testing provider before the US Department of Commerce regarding compliance with Entity List requirements and related export controls licensing, including overcoming a Notice of Intent to Deny an export license.
- Represented a Russian corporation before OFAC regarding the removal of US sanctions and related ongoing compliance and reporting requirements.
- Assisted a major US defense contractor with the development of a system of export control jurisdiction and classification assessments and related automation and policies and procedures to comply with export control reform requirements.
- Assisted several software companies with encryption export control classifications for hundreds of software items, developed tailored classification questionnaires, and trained internal teams for ongoing classifications.
- Conducted internal investigations regarding export controls and sanctions potential violations for ongoing compliance and for acquisitions, and drafted voluntary disclosures to the US State Department, the US Department of Commerce, and OFAC.
- Conducted an internal anti-corruption investigation for a Moscow subsidiary of a multinational corporation.
- Prepared and submitted classification requests before the US Department of Commerce for encryption and other dual-US items, and jurisdiction requests to the US State Department.
- Drafted comprehensive export controls, sanctions, anti-boycott, and anti-corruption policies and procedures, and related training materials, for a new acquisition of a defense contractor.
- Successfully appealed several personal security clearance denials for corporate executives.
- Conducted pre-acquisition due diligence and a post-acquisition export controls and sanctions audit for an acquisition of a cybersecurity corporation.
- Prepared US Department of Commerce and OFAC licenses applications for export of medical equipment to Cuban hospitals.
- Participated in international trade investigations before the US International Trade Commission in the softwood lumber dispute, including related NAFTA appeals, and represented a variety of industries in anti-dumping and countervailing duty disputes before US agencies and the US Court of International Trade and Federal Circuit, including a uranium antidumping appeal before the US Supreme Court.
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Conducted a global audit of Airbus' commercial and defense-related businesses as part of a monitorship requirement imposed on the company in connection with a consent agreement with the US Department of State, Directorate of Defense Trade Controls to settle allegations of export control violations under the International Traffic in Arms Regulations (ITAR).
Speaking Engagements
- "Foreign Direct Product rules in the spotlight: new and updated regulations, and unprecedented enforcement," WorldECR Export Controls and Sanctions Forum, Washington, DC, October 16, 2023
- "Significant EAR Violations and BIS Policy Shift: Incentivized Voluntary Self-Disclosure and Third-Party Whistleblowing," Strafford Webinar, September 13, 2023
- "Export Controls and Cloud Computing: Complying With ITAR, EAR, and Evolving Sanctions Laws," Strafford Publications, May 31, 2023
- "EAR anatomy – the Entity List under the microscope," WorldECR Virtual Forum, February 2022
- "Export Controls and Cloud Computing: Complying With ITAR, EAR, and Sanctions Laws," Strafford Webinar, August 11, 2021
- "Gazing into the Crystal Ball: How the Results of the November Election will Impact US Sanctions Policy Objectives and New Legislation Coming Down the Pike," ACI's Navigating Russia Sanctions Complexities Conference, November 10, 2020
- "Focus on Russia: How to Navigate the Import Restrictions and Avoid Potential Sanctions Violations," ACI's 9th Advanced Industry Forum on Global Encryption, Cloud & Cyber Trade Controls, San Francisco, CA, March 26, 2019
- "TCPs & TTCPs Best Practices: Top Five Pitfalls Avoid in Your TCPs & TTCPs," ACI's 11th Industry Forum on International Technology Transfers, Cloud Computing & Deemed Export Compliance, Washington, DC, February 6, 2019
- "Enforcement and Legal Regulation in the Era of Sanctions," Impact of Sanctions on the Russian Business and Investment Climate, Moscow, Russia, April 24, 2018
- "Russian Response to Western Sanctions: Countersanctions and their Impact," ABA Section of International Law, Washington, DC, November 17, 2015
- "Strategies for Dealing with Trade Sanctions & Restricted Parties, Antiboycott & FCPA," 3rd Annual Impact of Export Controls on Higher Education & Scientific Institutions, Washington, DC, 2015
News & Publications
Stepwise Risk Outlook
US Intelligence’s 2025 Worldwide Threat Assessment; Implications for Businesses
April 2, 2025
By: Melissa B. Mahle
International Compliance Blog
Trump Imposes Novel “Secondary Tariffs” on Countries Importing Venezuelan Oil and Petroleum Products
March 31, 2025
By: Steptoe's Economic Sanctions Practice
International Compliance Blog
Treasury Department Delists Tornado Cash Following the Fifth Circuit’s Decision
March 25, 2025
By: Steptoe's Economic Sanctions and Blockchain and Cryptocurrency Practices
Stepwise Risk Outlook
First Steps Towards Ending the Ukraine War Highlight Difficult Process and Business Risks Ahead
March 5, 2025
By: Melissa B. Mahle
Stepwise Risk Outlook
Georgian Dream Puts Breaks on EU Accession, Escalating Geopolitical Risks
December 5, 2024
By: Melissa B. Mahle
Stepwise Risk Outlook
How Iran’s Strategic Dilemma Underpins Ongoing Conflict in the Middle East
November 10, 2024
Stepwise Risk Outlook
Great Power Competition in the Arctic: Implications for International Trade
November 7, 2024
By: Melissa B. Mahle
Stepwise Risk Outlook
The China-India Border Détente and its Implications for US Indo-Pacific Interests
November 3, 2024
Stepwise Risk Outlook
"Total Victory" and the “Day After” in Gaza: Israel’s Calculus
October 29, 2024
By: Anni Coonan, Dan Arbell
Resources
Client Alerts
FCPA/Anti-Corruption Developments: 2020 Year in Review
January 19, 2021
By: Zoe Osborne, Brigida Benitez, Alexandra Baj, Christopher R. Conte, Alexandra Melia, Ali Burney, Fernando Q. Merino, Wendy Wysong, Jefferson Klocke, Jingchun (Cherry) Huang, Troy Shephard, Lin Yang, Bo Yue, Lucas Caiado (International Regulation & Compliance Intern), Jordan Cannon (Law Clerk), Marcia Pulcherio (International Trainee)
Client Alerts
Assessing the Impacts of Executive Order 13936 on Hong Kong's Status, One Month Later
August 25, 2020
By: Alexandra Baj, Ali Burney, Eric C. Emerson, Edward J. Krauland, Michelle L. Levin, Patrick F. Linehan, Meredith Rathbone, Wendy Wysong, Martin Willner, Jacob Nelson (International Trade Assistant)
Client Alerts
Commerce Issues Long-Awaited Export Control Rules for China, Russia, and Venezuela
April 30, 2020
By: Edward J. Krauland, Wendy Wysong, Meredith Rathbone, Alexandra Baj, Jack R. Hayes
Client Alerts
FCPA/Anti-Corruption Developments: 2019 Year in Review
January 21, 2020
By: Brigida Benitez, Wendy Wysong, Zoe Osborne, Steven J. Barber, Alexandra Melia, Ali Burney, Fernando Q. Merino, Alexandra Baj, Jefferson Klocke, Troy Shephard, Lin Yang, Bo Yue
Client Alerts
FCPA/Anti-Corruption Developments: 2018 Year in Review
February 28, 2019
By: Brigida Benitez, William L. Drake, Alexandra Melia, Fernando Q. Merino, Alexandra Baj, Evan T. Abrams, Lin Yang, Bo Yue, Troy Shephard
Client Alerts
FCPA/Anti-Corruption Developments: 2017 Year in Review & 2018 Q1 Preview
April 12, 2018
By: Brigida Benitez, William L. Drake, Alexandra Baj, Evan T. Abrams, Galen Kast, Lin Yang, Bo Yue
Client Alerts
New Sanctions Against Russian Oligarchs, Officials, and Companies May Have Significant Impact
April 12, 2018
By: Meredith Rathbone, Edward J. Krauland, Alexandra Baj, Evan T. Abrams
Client Alerts
A Detailed Look at the Countering America's Adversaries Through Sanctions Act
August 10, 2017
By: Meredith Rathbone, Zhu (Judy) Wang, Jack R. Hayes, Alexandra Baj
Client Alerts
ZTE Settlement Marked by Record Penalty and Lessons Learned
March 22, 2017
By: Edward J. Krauland, Meredith Rathbone, Alexandra Baj, Evan T. Abrams
Events
Webinars
Possible Sanctions Against Russia: What You Need to Know
February 9, 2022
Speakers: Meredith Rathbone, Edward J. Krauland, Alexandra Baj, Matthew Coleman, Alexandra Melia, Guy Soussan, David M. Stetson
Webinars
2015 Developments Regarding Economic Sanctions and Export Controls
December 15, 2015
Speakers: Alexandra Baj, Jack R. Hayes, Meredith Rathbone, Edward J. Krauland
Noteworthy
- Chambers Global, International Trade: Export Controls & Economic Sanctions, US (2023-2025)
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Chambers USA, International Trade: Export Controls & Economic Sanctions, Nationwide (2021-2024)