Keil J. Ritterpusch

How Keil Helps Clients

Keil has more than 20 years of experience representing clients in international trade, national security, and corporate/government investigation matters. Keil represents clients in all matters related to the U.S. export control laws and regulations and the U.S. laws and regulations related to economic and trade sanctions. Keil’s clients come from the defense, aerospace, high technology, encryption, computer, electronic device, software, medical, and private equity industries. Keil provides export compliance counsel in the context of acquisitions, investments, and divestitures involving foreign companies and export-regulated technologies, economic embargoes and sanctions, and supply chain security and compliance.

At the core of Keil’s expertise is an extensive knowledge of export jurisdiction and classifications for virtually all commodities that are regulated by the U.S. International Traffic in Arms Regulations (“ITAR”) and the U.S. Export Administration Regulations (“EAR”).  This gives Keil’s clients a technically skilled lawyer who can interface with engineering personnel, senior leadership, and business development personnel alike, while also being able to cogently analyze export compliance requirements and prepare the appropriate export licenses, export jurisdiction and classification documentation, and government filings.

This skill set has led Keil to provide extensive support to clients with respect to their compliance with the ITAR, the EAR, and the Foreign Trade Regulations (“FTR”), and the preparation and filing of more than a hundred Voluntary Disclosures (“VDs”) with the U.S. Department of State, U.S. Department of Commerce, Census Bureau, and U.S. Department of Treasury in relation to findings of matters of non-compliance with applicable U.S. export control laws and regulations and embargoes and sanctions compliance.  These VD filings have arisen from findings of matters of non-compliance in the course of conducting export-related due diligence in mergers & acquisitions, preparing export jurisdiction and classification analyses, performing export and sanctions compliance audits and assessments, the development and implementation of compliance programs, and the preparation of export licensing applications.

Keil assists clients with the formation or revision and implementation of compliance programs to ensure that the clients have the appropriate systems in place for complying with the ITAR, EAR, FTR, OFAC regulations, Foreign Corrupt Practices Act (“FCPA”), and other foreign country bribery requirements, and anti-boycott rules of the Department of Commerce. He supports clients through various requirements related to cybersecurity and general corporate compliance.

As part of his representation of clients in relation to mergers, acquisitions, and divestitures, Keil has provided counsel on the requirements of the Committee for Foreign Investment in the United States (“CFIUS”) for foreign investments in key U.S. industries and the CFIUS clearance process.  Keil has led detailed export jurisdictional and classification assessments for an array of proposed investments of foreign interests into U.S. companies and shepherded cases through the review process with the U.S. Department of State and CFIUS.  Keil routinely performs critical technology evaluations in connection with prospective foreign investments to aid in the determination of mandatory or voluntary CFIUS filing requirements.

What Clients Can Expect

Clients praise Keil for his exceptional technical acumen and ability to understand the core technologies involved with their enterprises and ability to coherently explain how the U.S. export control regulations apply to their business activities and products, both when products and services will be exported and where clients will engage the direct support of foreign persons in their operations. Clients also appreciate the pro-business approach that Keil takes to ensure that compliance systems are implemented to ensure the minimum required impediments to business activities.  Keil takes pride in not only helping clients with their current export compliance requirements, but also carefully considering how product development can be modularized to ensure that companies have baseline products with minimal export requirements, while having add-ons and customizations to baseline products for an array of export markets.

I help clients to embed export compliance into their business activities. I train clients to think about export issues in a strategic way, similar to how they think about the prices they charge in order to achieve maximum profits. 

Outside the Office

Keil enjoys spending time with his wife, especially when paddleboarding on one of the many Northern Virginia lakes or on the Tidal Basin.  Keil has two children one a graduate of Virginia Tech who works for the Institute for Justice and the other a student at James Madison University.  Keil enjoys watching sports, including college football, women’s college lacrosse, and women’s college field hockey ‒ especially when his alma mater, Northwestern University, is playing.  Keil coached field hockey at the high school varsity and travel team level for many years, before retiring from coaching in 2019.

Proof Points 

Export Controls/Compliance

• More than one hundred Voluntary Disclosures prepared on behalf of clients under the ITAR, EAR, FTR, and OFAC regulations; no client has been fined by the U.S. Government.
•  Advise major defense contractor with complex licensing and classification matters and Foreign Military Sales matters.
•  Advise electronic device manufacturer on export jurisdiction and classification matters related to product sales for use in various military applications.
•  Advise billion dollar computing and memory company on all aspects of export compliance, especially with regard to complex China semiconductor and supercomputer rules under the EAR.
•  Advise Korean semiconductor developer and manufacturer on requirements under China semiconductor and semiconductor rules with regard to manufacturing operations in Korea and China and restrictions on U.S. persons in senior management and operations of Chinese affiliate.
•  Assisted Korean semiconductor company in obtaining export licensing under EAR for exports intended for certain parties in China.
•  Assisted numerous electronic component and device manufacturers with the development of export, sanctions, and embargo compliance programs.
•  Provide export classification and jurisdiction support and export licensing for Irish telecommunications and computing manufacturer selling products to the U.S. military through its U.S. subsidiaries.
•  Assisted major European manufacturer of military aircraft with U.S. export requirements for sale of fighter jets with significant U.S. content to the Kingdom of Saudi Arabia.

Merger, Acquisition, Divestiture, and Investment Export Due Diligence and CFIUS

• Represent major corporations operating globally in the aerospace, defense and security sectors; provide advice and counsel concerning US national security regulatory approvals for acquisitions, including export control compliance matters before the Department of State and the Department of Commerce.
•  Assisted ruggedized computer company with respect to CFIUS clearance process and export jurisdiction and classification analysis in relation to acquisition by Israeli company.
•  Provided complex export jurisdiction and classification support and worked on divestiture required for the U.S. arm of a German multinational corporation being acquired by a Chinese corporation, supporting the German parent and its U.S. subsidiary with the approvals required for the sale under the ITAR ‒ interfacing with DDTC ‒ and before CFIUS.
•  Provided export jurisdiction and classification support in connection with the acquisition by an Italian company of an ITAR registered company in the coatings and surface treatments industry with defense applications and the requirements under the ITAR and CFIUS.