Admissions
- Washington, DC
- North Carolina
- Pennsylvania
Education
- Georgetown University JD, MSFS, 1992
- University of North Carolina at Chapel Hill, BA, 1988
- BA awarded with highest distinction, 1988
- Chemistry Award, 1985
Overview
Mr. 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”) and the Department of Energy.
Mr. Gold has advised clients in a variety of industries, such as the software, computer, semiconductor, telecommunications, test equipment, financial, aerospace, defense, agricultural irrigation, medical equipment, 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.
Representative Experience
- Provide U.S. and non-U.S. companies with compliance advice and risk assessments of proposed exports, reexports, and in-country transfers, and other proposed transactions.
- Prepare applications for Commerce licenses, including export licenses, reexport licenses (including in-country transfers), Encryption License Arrangements, deemed export licenses, and deemed reexport licenses.
- Advise companies on the export control classifications of their products and technologies. Prepare requests for formal Commerce classifications of products.
- Advise companies on export controls and sanctions governing encryption, cloud computing, and artificial intelligence.
- Prepare General Correspondence requests to State seeking authorization of proposed reexports, proposed retransfers, and proposed U.S. person services abroad.
- Prepare requests to State for commodity jurisdiction determinations.
- Prepare applications for Treasury specific licenses.
- Prepare compliance programs and technology control plans. Prepare export compliance contract clauses.
- Prepare voluntary self-disclosures to Commerce, State, Treasury, and Energy. Prepare Prohibition 10 requests to Commerce. Advise companies on corrective procedures.
- Advise companies on compliance with Commerce antiboycott controls and Treasury antiboycott controls.
Practice Focus
- Export Controls
- Sanctions
- Antiboycott
Professional Affiliations/Recognition & Awards
- Treasurer and Member of Board of Directors, National Council on International Trade Development
Publications
- 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.
- Ben Flowe & Ray Gold, Legal Aspects of U.S. Sanctions, Global Dialogue, Center for World Dialogue, Summer, 2000.
- Clarence Ditlow & Ray Gold, Little Secrets of the Auto Industry, Moyer Bell (1994).
Speaking
- Extraterritorial Application of US Export Controls — ITAR and EAR, Global Business Lawyers Alliance Conference, April 18, 2024.
- Overview of U.S. Commerce Department’s Encryption Export Controls, Automotive Industry Action Group’s 2016 Customs Town Hall, November 15, 2016.
- 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.
- Commerce Department Export Controls and Treasury Department Embargoes/Sanctions: Impact on Canadian Entities, Ottawa Centre for Research and Innovation, October 24, 2008.
- Compliance with US Export and Reexport Controls, International Safety Equipment Association, November 12, 2007.
- EAR Deemed Export Rule, Washington Metropolitan Area Corporate Counsel Association, March 23, 2000.