Has more than 30 years’ experience providing advice and counseling regarding the laws, regulations, policies, practices and politics pertaining to export controls, sanctions, national security reviews of foreign direct investments and other international trade issues.
Has deep experience that includes civil and criminal defense, internal investigations, due diligence audits and compliance program enhancements, as well as being a Special Compliance Officer.
Served as Assistant Secretary of Commerce for Export Administration, Bureau of Industry and Security (BIS).

Kevin’s practice focuses on the:

Export Administration Regulations (EAR)
International Traffic in Arms Regulations (ITAR)
Regulations administered by the Committee on Foreign Investment in the United States (CFIUS)
U.S. international trade policies
Regulations administered by the Office of Foreign Assets Control (OFAC).

In his role at the Commerce Department, Kevin’s primary responsibilities included:

Developing and implementing policies pertaining to the administration of U.S. export controls, particularly the licensing requirements of the EAR.
Representing the Commerce Department in meetings of CFIUS.
Developing and implementing, with Obama administration leadership and career staff, the Export Control Reform (ECR) initiative, which primarily pertained to revising the structure of defense trade controls.

Representative Work

Serves as the Special Compliance Officer for the U.S. State Department to monitor a multinational company’s compliance with the ITAR and requirements of a consent agreement.
Advises U.S. semiconductor and other high-technology companies regarding compliance with the EAR, including the prohibitions pertaining to activities involving foreign companies on the EAR’s Entity List, Denied Persons List and Unverified List.
Advises U.S. space, launch and aircraft companies regarding complex jurisdictional, classification, interpretation and licensing issues associated with the controls of the ITAR and the EAR.
Provides advice to companies regarding the applicability of the Treasury Department’s CFIUS regulations to transactions and business plans, particularly with respect to matters involving “critical technologies.”

Provides day-to-day advice and formal opinions in most technology sectors regarding complex export control jurisdiction, classification, interpretation and licensing matters.
Defends individuals and corporations under investigation for civil and criminal violations of export control and sanctions regulations.
Leads company-wide export control, sanctions and foreign direct investment compliance program reviews, enhancements and due diligence efforts.
Conducts extensive training for companies in multiple industries regarding the scope, meaning and application of U.S. export control and sanctions laws and regulations.
Conducts internal export control compliance investigations and, as warranted, the preparation of voluntary disclosures and related corrective action measures.

"He is incredibly knowledgeable and does a great job of using his extensive experience in practice and government to give straightforward advice."

Chambers USA, 2022

Education
J.D., University of Minnesota Law School, 1992
M.A., University of Minnesota, 1992
B.A., University of Missouri - Columbia, 1988

Bar Admissions
District of Columbia
Missouri

Recognitions

Chambers USA, International Trade: Export Controls & Economic Sanctions, 2018-2024.
The Legal 500, Leading Lawyer, 2024 and International Trade, 2018-2019 and 2021-2024.
Chambers Global, International Trade: Export Controls & Economic Sanctions, USA, 2019-2024.
The BTI Consulting Group, Client Service All-Star, 2020, 2022 and 2023.
The Best Lawyers in America, International Trade and Finance Law, 2018-2022.
Who’s Who Legal, Trade & Customs, 2018.
WorldECR Awards, Export Control Practitioner of the Year, 2017.

Affiliations and Public Service

Assistant Secretary of Commerce for Export Administration, Bureau of Industry and Security, 2010-2017.

Speeches and Publications

Panelist, “The Intersection of National Security and End-User Screening: Implications for Export Control Regulations,” Webinar, Kharon/Akin, March 12, 2024.
Speaker, “2023 Export Control Year-in-Review,” Webinar, Massachusetts Export Center's Export Expo, January 25, 2024.
Presenter, “Authority for Plurilateral Controls and a Multilateral Export Control Regime are Needed to Address Contemporary National Security and Human Rights Issues,” published in the Trade and Security report by the Korean Security Agency of Trade and Industry, June 2023, with Emily Weinstein, Research Fellow at Georgetown’s Center for Security and Emerging Technology.
Testimony before the House Committee on Foreign Affairs Subcommittee on Oversight and Accountability, “Reviewing the Bureau of Industry and Security, Part I U.S. Export Controls in an Era of Strategic Competition,” May 11, 2023.
Guest, “The Present and Future of U.S. Export Control Policy with Kevin Wolf,” Geoeconomic Agenda, April 20, 2023.
Testimony before the Senate Committee on Banking, Housing and Urban Affairs, “Advancing National Security and Foreign Policy Through Sanctions, Export Controls and Other Economic Tools,” February 28, 2023.
Testimony before the United Kingdom. The following are written comments submitted to the UK Parliament, Committees on Arms Export Controls, in support of the Committees’ December 7, 2022, session on “Strategic Export Controls and Russia.”
Speaker, “Strategic Export Controls and Russia,” Webinar, Committees on Arms Export Controls, December 2, 2022.
Comments of Kevin Wolf, Emily Kilcrease, and Jasper Helder Regarding Areas and Priorities for U.S. and EU Export Control Cooperation under the U.S.-EU Trade and Technology Council, January 14, 2022.
Speaker, “Foreign Investment and Export Controls?,” 2021 WITA Virtual Intensive Trade Seminar, September 13, 2021.
Testimony before the U.S.-China Economic and Security Review Commission Hearing on “U.S.-China Relations in 2021: Emerging Risks,” “Assessing Export Controls and Foreign Investment Review,” September 8, 2021.
Speaker, “Geostrategic Hardware Competition,” Webinar, CNAS Task Force, May 17, 2021.
Speaker, “Export Controls: Year in Review – A Look Back and Ahead,” Webinar, PLI’s Coping with U.S. Export Controls and Sanctions 2020, December 10, 2020.
Speaker, “Washington Perspectives on Export Controls and the Semiconductor Industry” Webinar, May 28, 2020.
Speaker, “Trade and National Security: What Trade and Customs Practitioners Need to Know,” Georgetown Law School’s 2020 International Trade Update, Washington, D.C., March 6, 2020.
Speaker, “Controlling U.S. Tech Exports to China: How to Get It Right,” Information Technology and Innovation Foundation, Washington, D.C., February 18, 2020.
Testimony, “Confronting Threats from China: Assessing Controls on Technology and Investment,” Senate Committee on Banking, Housing and Urban Affairs, Washington, D.C., June 4, 2019.
Testimony, “China in Space: A Strategic Competition,” U.S.-China Economic and Security Review Commission, Washington, D.C., April 25, 2019.
Testimony, “Perspectives on Reform of the CFIUS Review Process,” House Energy and Commerce Committee Subcommittee on Digital Commerce and Consumer Protection, Washington, D.C., April 26, 2018.
Testimony, “Modernizing Export Controls: Protecting Cutting-Edge Technology and U.S. National Security,” House Committee on Foreign Affairs, Washington, D.C., March 14, 2018.
Testimony, “Examining the Operations of the Committee on Foreign Investment in the United States (CFIUS),” House Committee on Financial Services, Subcommittee on Monetary Policy and Trade, Washington, D.C., December 14, 2017.
Testimony, “Examining the Committee on Foreign Investment in the United States,” Senate Banking, Housing and Urban Affairs Committee, Washington, D.C., September 14, 2017.
Kevin is a prolific keynote and panel speaker on export control and CFIUS issues at conference, trade association, industry and university events.