Christopher B. Stagg

Christopher Stagg leads Holland & Knight's Export Control Disputes and Advocacy Team, a dedicated and multidisciplinary practice that he pioneered within the legal industry, and the ITAR and Defense Trade Compliance Team.

Mr. Stagg solves complex and high-stakes export control challenges with a 360-degree perspective that integrates three critical roles – former export controls regulator, export controls white collar defense attorney and export controls litigator – into a unified strategy. This approach earns high praise, with the chief compliance officer of a publicly traded company calling his agency advocacy "terrifyingly good" at securing the regulator's trust and approval, while the trade press describes him as a "trailblazing attorney."

Mr. Stagg has shaped export control laws from inside and outside government. As an export controls regulator, he was an architect of the current regulatory framework. He later obtained the only judicial appellate decision ever rejecting the agency's interpretation of the International Traffic in Arms Regulations (ITAR). He also achieved prominent victories before the regulatory agencies. He led the defense of a proposed charging letter for a leading aerospace company, resulting in one of the most favorable settlements in ITAR enforcement history. Additionally, he led a consent agreement jurisdiction and classification review under intense government scrutiny, with the regulators approving his methodology without changes.

As senior policy advisor at the U.S. Department of State's Directorate of Defense Trade Controls (DDTC), Mr. Stagg was deputy lead for Export Control Reform, rewriting the ITAR and Export Administration Regulations (EAR), including the entire U.S. Munitions List. In that role, he worked on National Security Council interagency policy subcommittees with the U.S. Department of Commerce's Bureau of Industry and Security and the U.S. Department of Defense's Defense Technology Security Administration. He also authored the new U.S. policy for determining which items belong on the U.S. Munitions List and authoritatively interpreted the ITAR; he substantially reformed the interagency commodity jurisdiction procedure by revising how the government reviews cases and resolved hundreds of jurisdictional requests (including appeals). In addition, he advised on hundreds of civil and criminal investigations with DDTC's compliance office, the U.S. Department of Justice, the FBI and the Export Enforcement Coordination Center.

Mr. Stagg brings rare export control litigation experience that shapes his approach to every matter from the outset. He secured a landmark federal appellate victory rejecting DDTC's ITAR interpretation – a unanimous decision – along with multiple district court wins that the government did not appeal. He also originated a novel legal argument that 19 state attorneys general used to successfully challenge the ITAR's statutory authority, a challenge the government likewise did not appeal. This litigation experience enables Mr. Stagg to identify legal issues and strategic opportunities that often become apparent only through the lens of an experienced export controls litigator.

Mr. Stagg's strategic counsel often occurs under existing or expected government scrutiny, including potential criminal exposure and multi-agency investigations. He has advised six companies on navigating consent agreements by working with the government and appointed monitor to implement remedial actions and new compliance programs. He negotiates consent agreements, handles investigations and disclosures, and defends against alleged violations, including securing no-penalty resolutions in egregious cases. He also leads major jurisdiction and classification reviews, including personally classifying more than 80,000 items under a consent agreement. Additionally, he resolves challenging and cutting-edge jurisdiction, classification and regulatory issues.

Beyond his practice, Mr. Stagg co-chairs the American Bar Association's (ABA) Export Controls and Economic Sanctions Committee and is a fellow of the American Bar Foundation. He is also a distinguished author, serving as the editor of Bartlett's Annotated International Traffic in Arms Regulations and is a contributing author to the leading treatise United States Export Controls (Law Journal Press). In addition, he co-edited the export control developments section for the ABA's annual Year in Review publication from 2013 to 2023. He is featured or quoted in leading publications, including The Wall Street Journal and Bloomberg, and he frequently speaks at events such as the Society for International Affairs and the American Conference Institute.