Keil J. Ritterpusch

How Keil Helps Clients

Keil represents clients in international trade, national security, and corporate/government investigation matters. With more than 20 years of experience, he focuses his practice on all matters related to the U.S. export control and economic and trade sanctions laws and regulations. Keil’s clients come from the defense, aerospace, technology, encryption, computer, electronic device, software, medical, and private equity industries. He 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 skill set has also led Keil to provide extensive support to clients with respect to their compliance with the Foreign Trade Regulations (FTR.) Keil has also been at the forefront of more than a hundred Voluntary Disclosures submissions with the U.S. Department of State, U.S. Department of Commerce, Census Bureau, and U.S. Department of Treasury in relation to matters of noncompliance with applicable. As a result, each of Keil’s clients are assured that they are working with a technically skilled lawyer who can interface with engineering personnel, senior leadership, and business development personnel alike.

Keil helps clients handle a wide array of issues pertaining to the importation of goods. His expertise includes tariff classification, valuation, country of origin labeling, free trade agreements, and specialized trade programs. With extensive experience in customs compliance, he consistently assists importers facing audits, penalties, seizures, redelivery notices, and various enforcement actions initiated by U.S. Customs and Border Protection (CBP).

Keil’s comprehensive knowledge and hands-on support enables clients to effectively navigate the complexities of customs regulations and minimize the potential implications of such. Having worked on a multitude of matters involving imported goods, Keil has garnered experience with various agencies that are leading influencers of international trade and trade policy. These agencies include, but are not limited to, the International Trade Commission (ITC), the Department of Commerce (DOC), the U.S. Trade Representative (USTR), the Consumer Product Safety Commission (CPSC), the Food and Drug Administration (FDA), and the Fish and Wildlife Service (FWS).

He is dedicated to helping clients effectively manage CBP detentions, seizures, and forfeitures, and reduce fines and penalties. He also assists in addressing CBP Requests for Information (CBP Form 28), responding to Notices of Action (CBP Form 29), and filing Protests with CBP. Keil is experienced  in supporting companies to address supply chain security concerns, including enrollment, verification, and annual reviews for the Customs-Trade Partnership Against Terrorism (C-TPAT) and guiding them through the validation process.

Most significantly, he collaborates closely with both importers and exporters to proactively identify cost-saving opportunities and develop programs that align with CBP’s highest standards of compliance. His particular expertise spans a diverse range of imported products, representing companies from diverse high-tech to traditional industries ranging from electronics, lumber and paper, textile, food, petroleum, to steel and construction, automotive, chemical, and defense products.

As part of his representation of clients in relation to mergers, acquisitions, and divestitures, Keil has provided counsel on the Committee for Foreign Investment in the United States (CFIUS) requirements for foreign investments in key U.S. industries and their clearance process. Keil has led detailed jurisdictional and classification assessments for an array of proposed foreign interest investments 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.

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.

What Clients Can Expect

Clients praise Keil for his exceptional technical acumen and ability to understand the core technologies involved with their enterprises. They appreciate his 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.

Clients have disclosed that one of the many distinguishing factors that differentiates Keil from other customs attorneys is his proactive approach. By efficiently leveraging his extensive expertise, Keil focuses not only on addressing issues as they emerge, but also on "preventive law" strategies that are designed to avert potential problems before they occur. By prioritizing prevention, Keil empowers his clients to operate smoothly and avoid costly disruptions, setting him apart in the field of customs law. This forward-thinking mindset also allows clients to conduct their business with greater confidence, knowing that they have a solid framework in place to minimize risks and navigate the complexities of customs regulations effectively.

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.