Ray Gold
… focuses on U.S. export control and sanctions laws and regulations, including the Commerce Department's Export Administration Regulations ("EAR"), the State Department's International Traffic in Arms Regulations ("ITAR"), and regulations administered by the Treasury Department's Office of Foreign Assets Control ("OFAC"), the Nuclear Regulatory Commission, and the Department of Energy.
Mr. Gold has advised clients in a variety of industries, such as the computer, software, semiconductor, test equipment, telecommunications, automotive parts, financial, aerospace, satellite, defense, agricultural irrigation, and nuclear industries. Mr. Gold advises both U.S. and non-U.S. based companies on the application of U.S. export control and sanction laws and regulations to their exports and to the conduct of their non-U.S. business.
Mr. Gold has advised on a wide range of export control and sanctions matters, such as transaction due diligence, licensing, classification/commodity jurisdiction, internal investigations, voluntary disclosures, compliance programs and procedures, ITAR registrations, U.S. Person Abroad ("USPAB") requests, de minimis and direct product rules, and license exceptions / exemptions / general licenses. Mr. Gold also has substantial expertise with U.S. antiboycott laws.
Mr. Gold re-joined BCR in 2005 after spending a year as Counsel, Export Controls and Government Contracts (the top U.S. export control official) for Thales North America, Inc., which was then the North American headquarters of the Thales Group, an international leader in defense, aerospace, and information technology.
Professional AffiliationsMr. Gold is on the Board of Directors of the National Council on International Trade Development, which is a nonprofit organization dedicated to providing expertise on international trade topics, especially U.S. export control laws and regulations.
Partner
Tel: +1 (202) 293-5555
Fax: +1 (202) 293-9035
EMail: RGold@bcrlaw.com
Export Controls and Sanctions
Georgetown University (J.D., 1992; M.S.F.S., 1992)
University of North Carolina at Chapel Hill (B.A., with highest distinction, in History, 1988; Chemistry Award, 1985)
District of Columbia
North Carolina
Pennsylvania (inactive)
• Clarence Ditlow & Ray Gold, Little Secrets of the Auto Industry, Moyer Bell (1994).
• Ben Flowe & Ray Gold, Legal Aspects of U.S. Sanctions, Global Dialogue, Center for World Dialogue, Summer, 2000.
• Ben Flowe & Ray Gold, Legal Aspects of U.S. Sanctions, Economic Sanctions, American Bar Association Section of International Law and Practice and the Center for Continuing Legal Education, 2001.
• Overview of U.S. Commerce Department's Encryption Export Controls, Automotive Industry Action Group's 2016 Customs Town Hall, November 15, 2016.
• Extraterritorial Application of US Export Controls — ITAR and EAR, Global Business Lawyers Alliance Conference, April 18, 2024.
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EAR Deemed Export Rule, Washington Metropolitan Area Corporate Counsel Association, March 23, 2000.
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Compliance with US Export and Reexport Controls, International Safety Equipment Association, November 12, 2007.
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Commerce Department Export Controls and Treasury Department Embargoes/Sanctions: Impact on Canadian Entities, Ottawa Centre for Research and Innovation, October 24, 2008.
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Need for Effective Export Compliance Programs and Elements of Such Programs, guest speaker for a course ("U.S. Export Control Law and Regulation") at George Washington University Law School, November 12, 2012.