Meshkat Law represents organizations and individuals facing potential liability under the Export Administration Regulations (EAR), including its antiboycott provisions. We help clients navigate matters involving the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and its Office of Export Enforcement (OEE) at every stage—from the first sign of potential EAR issues through internal review, engagement with BIS, resolution of enforcement actions, and, where appropriate, litigation and coordination with parallel proceedings.
BIS is responsible for administering and enforcing the EAR, which govern a wide range of exports, reexports, and in-country transfers with national security and foreign policy implications. Within BIS, export enforcement functions—including the Office of Export Enforcement (OEE)—focus on identifying potential violations and enforcing compliance through investigations and administrative actions.
BIS has authority to pursue civil monetary penalties, denial of export privileges, and other administrative measures where it determines that the EAR or related antiboycott rules have been violated. In more serious cases, including those involving willful conduct, BIS can also refer matters to the U.S. Department of Justice (DOJ) for potential criminal prosecution.
Companies frequently encounter BIS and OEE through requests for export-related records that must be maintained under the EAR or through administrative subpoenas seeking documents and testimony. BIS’s published enforcement and penalty guidance places significant weight on how organizations respond to apparent violations—particularly whether they disclose issues, cooperate, remediate underlying gaps, and strengthen their export compliance programs.
Meshkat Law represents clients responding to BIS and OEE administrative subpoenas and other requests for records or information relating to potential EAR issues. We work quickly to help clients preserve relevant materials, understand the scope of BIS’s requests, assess their exposure under the EAR, and, where appropriate, seek clarifications or reasonable extensions while maintaining a cooperative posture. Our work includes coordinating document collection and review, preparing accurate and carefully framed written responses, and managing communications with BIS in a way that protects the client’s legal position and privilege while addressing the agency’s enforcement expectations.
Kian Meshkat helps clients manage investigations and enforcement risk at every stage. He has previously served as a subject matter expert and consultant to the court-appointed independent monitor team in the largest sanctions and export controls monitorship in U.S. history.
We assist clients in assessing potential EAR violations—including its antiboycott rules—and, where appropriate, preparing voluntary self-disclosures (VSDs) to BIS. Our role often includes overseeing internal fact-finding, analyzing whether the conduct constitutes one or more apparent violations, and evaluating the risks and benefits of a VSD in light of BIS’s published enforcement and penalty guidance under the EAR, together with the client’s business operations, risk profile, and broader commercial considerations. We prepare detailed disclosure submissions that explain the relevant facts, provide legal analysis, and describe remedial and compliance measures, and we engage with BIS throughout its review, including responding to follow-up questions and aligning additional remediation with the overall narrative of the disclosure.
We represent clients in BIS administrative enforcement matters, including responding to charging letters, engaging in settlement discussions, and, where necessary, representing clients in formal administrative proceedings under the EAR’s administrative enforcement provisions. We evaluate BIS’s factual and legal theories, develop defenses, and actively engage with BIS regarding proposed civil penalties, denial orders, and any required remedial commitments, with the goal of securing the best possible outcome for our clients.
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Responding to BIS and OEE Subpoenas and Other Requests