Christopher B. Stagg

Christopher Stagg is an export controls and national security attorney in Holland & Knight's Tysons office.

With significant experience writing and heavily influencing U.S. export control laws, companies turn to Mr. Stagg as their "go-to" lawyer for high-stakes situations and cutting-edge legal strategies to increase their likelihood of success. From publicly traded companies to startups, companies rely on him for his extensive track record of success, stemming from his top-notch advocacy, unparalleled experience, sound judgment and legal strategy. Beyond his client work, Mr. Stagg serves as co-chair of the American Bar Association's (ABA) Export Controls and Economic Sanctions Committee.

Mr. Stagg served as a senior policy advisor at the U.S. Department of State's Directorate of Defense Trade Controls (DDTC), where he was deeply involved in writing export control regulations and revising the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), along with the U.S. Munitions List and Commerce Control List. He was also responsible for authoritatively interpreting the ITAR, reforming the ITAR's commodity jurisdiction procedure, resolving more than 500 commodity jurisdiction requests and appeals, working with the FBI on export enforcement investigations, and handling bilateral and multilateral defense trade issues.

Through his experience, Mr. Stagg has developed the rare distinction of successfully litigating export control issues against the government, including the only appellate decision to reject DDTC's interpretations of the ITAR. In that case, DDTC interpreted the ITAR so that prior government authorization is required for technical data to qualify as information in the public domain. The U.S. Court of Appeals for the Second Circuit unanimously rejected DDTC's interpretation, ruling that: "Nowhere do the ITAR state or imply that prior government authorization is required for information to qualify as in the public domain." Additionally, Mr. Stagg originated a novel legal argument – later successfully used by 19 state attorneys general as the lead argument – that DDTC exceeds its statutory authority under the Arms Export Control Act (AECA) when removing individual articles from the U.S. Munitions List without congressional notification.

In addition, Mr. Stagg's practice focuses on high-stakes export control matters by leveraging his extensive government and litigation experience to develop effective legal strategies and identify novel legal issues. For instance, he works with companies to defend against alleged export control violations and advises on litigation. That experience includes leading the enforcement defense for a prominent global aerospace and defense company in response to a contested proposed charging letter, using a legal strategy that led to the longest-known defense of a proposed charging letter in history and ultimately to a favorable settlement. It also includes successfully defending companies in enforcement cases where there was a substantial likelihood of receiving a proposed charging letter. In addition to defending against and negotiating consent agreements, he has advised five publicly traded companies on complying with their ITAR consent agreement requirements. He has also successfully advocated for regulatory revisions and favorable interpretations for his clients.

Mr. Stagg also has a leading practice for resolving jurisdiction, classification and interpretative issues. That practice includes successfully representing numerous companies in commodity jurisdiction and classification requests, including securing reversals of adverse agency decisions through appeals and reconsiderations. He also handles these issues where there is intense government scrutiny, such as under consent agreements to review the jurisdiction and classification of the company's items. He recently led the jurisdiction and classification review for a publicly traded company under a consent agreement that involved examining more than 80,000 items and his methodology was approved by DDTC without any changes. He also resolves complex jurisdiction and classification issues where companies require high-confidence self-determinations, and he resolves the most perplexing interpretative issues, such as the scope of ITAR technical data controls.

Mr. Stagg's professional experience includes serving as in-house counsel for a Fortune Global 100 company, working as an export controls lawyer at several distinguished law firms, and founding his award-winning firm that earned "highly commended" recognition from WorldECR.

Mr. Stagg holds several prestigious positions that underscore his authority in export controls. In addition to serving as co-chair of the ABA's Export Controls and Economic Sanctions Committee, he has been inducted as a fellow of the American Bar Foundation and is the assistant editor of Bartlett's Annotated International Traffic in Arms Regulations. He also served 10 years as the co-editor of the ABA's Year-in-Review for export controls and economic sanctions.

Mr. Stagg has been featured or quoted by many leading publications on export control matters, including the Wall Street Journal, Law360, Bloomberg, Global Investigations Review, Export Compliance Daily, WorldECR and Export Compliance Manager. He has been a speaker at prominent industry events, such as the American Bar Association, Society for International Affairs and American Conference Institute, among others. He has taught export controls courses for the Export Compliance Training Institute since 2015, where he teaches on jurisdiction and classification and enforcement defense, and for the American Conference Institute since 2021, where he teaches on ITAR jurisdiction and classification. He also served 10 years as the co-editor of the American Bar Association's Year-in-Review for export controls and economic sanctions.

While in law school, Mr. Stagg clerked for the U.S. Attorney's Office for the Southern District of Illinois, and previously interned twice for the U.S. Department of Justice's (DOJ) Civil Division, Aviation, Space and Admiralty Litigation Section of the Torts Branch.

Not yet admitted to Virginia Bar; admitted to New York Bar and District of Columbia Bar only and practicing under supervision of lawyers licensed to practice in Virginia.