Maria Alejandra (Jana) del-Cerro

Overview

Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures. Jana previously worked at the Department of State’s Directorate of Defense Trade Controls (DDTC) and currently serves as a member of the U.S. Department of State Defense Trade Advisory Group (DTAG).

As an International Trade partner, Jana works with U.S. and non-U.S. clients on all aspects of export compliance, including day-to-day compliance counseling, developing compliance programs, completing commodity jurisdiction and classification analysis, conducting export trainings, and performing M&A due diligence and coordinating related regulatory submissions.

As part of her practice, Jana regularly:

Represents companies in responding to compliance inquiries related to the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR), the Export Control Reform Act (ECRA), and the Export Administration Regulations (EAR).
Manages internal investigations and compliance reviews with respect to export compliance.
Represents clients with respect to voluntary disclosures to the Departments of State, Commerce, and Treasury, and related administrative DDTC and Bureau of Industry and Security (BIS) licensing and approvals.
Analyzes and advises U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, or hardware.
Performs jurisdictional and classification analyses under the ITAR and EAR, including drafting and submission of CJ and CCATS requests.
Develops and/or reviews U.S. export and sanctions compliance programs.
Performs M&A trade due diligence for both buy side and sell side clients, specifically on issues related to compliance with U.S. export controls and sanctions programs.
Counsels ITAR-registered companies on M&A regulatory requirements (60-day and five-day notices to DDTC under the ITAR) and transfer of DDTC and BIS authorizations.

Career & Education

|

Department of State

Member, Defense Trade Advisory Group, 2024–Present

Regulatory and Multilateral Affairs Analyst, Policy Office, Directorate of Defense Trade Controls, 2021–2022
- Department of State
  - Member, Defense Trade Advisory Group, 2024–Present
  - Regulatory and Multilateral Affairs Analyst, Policy Office, Directorate of Defense Trade Controls, 2021–2022
University of Virginia, B.A., history, 2004
American University Washington College of Law, J.D., With Honors, 2008
American University School of International Service, M.A., international affairs, 2008
- University of Virginia, B.A., history, 2004
- American University Washington College of Law, J.D., With Honors, 2008
- American University School of International Service, M.A., international affairs, 2008
District of Columbia
Virginia (Inactive)
- District of Columbia
- Virginia (Inactive)

Jana's Insights

Client Alert | 9 min read | 12.03.24

The Month in International Trade – November 2024

Erik Woodhouse, Former Department of State Sanctions Official, Returns to Crowell & Moring...

Publication | 12.02.24
U.S. Department of State Publishes International Traffic In Arms Regulations Amendments To Implement The AUKUS Exemption
Client Alert | 7 min read | 11.27.24
CFIUS Finalizes Regulations to Increase Penalties, Expand Subpoena Authority, and Enhance Enforcement Authorities to Protect National Security
Client Alert | 8 min read | 11.12.24
The Month in International Trade – October 2024

View All Insights

Representative Matters

Advised on legal strategy and managed export attorney and consultant teams in multinational corporation’s internal investigation arising from apparent transfers and storage of ITAR and EAR-controlled technical information in a cloud-based global network.
Represented large defense contractor in investigation and voluntary disclosure to DDTC in connection with overseas payments of fees and commissions, and related reporting under ITAR Part 130 to DDTC.
Counseled non-U.S. semiconductor manufacturing equipment producer on applicability of EAR end user and end use licensing requirements, and the EAR Foreign Direct Product Rules, on client’s sales throughout Asia.
Directed export classification review of a quantum company’s hardware and related technology and software, as well as navigating changing EAR export controls on quantum technologies, and assisted company with development of policies and procedures to enhance export compliance.
Managed a global sensors and electronics companies’ internal investigation of overseas production of export-controlled sensor and related unlicensed technology transfers, and represented the client in a related voluntary self-disclosure to BIS.
Assisted client with internal investigation and represented client in voluntary self-disclosure to BIS regarding sales of engineering software to Entity List party subject to a BIS heightened Foreign Direct Product rule, and performed U.S. export jurisdictional analysis of the software involved.
Represented aerospace and defense contractor in internal review of export control policies and procedures, and assisted in responding to DDTC Requests for Information regarding foreign person access to technical data.
Assisted client in internal investigation of foreign affiliate sales to Russian distributors, including transactional analysis of items exported since 2022, and represented client in voluntary self-disclosure to BIS.
Provided legal advice for client’s export classification review of entire UAV system, including preparing and submitting export commodity classification requests to BIS regarding various software packages and related technology.
Regularly performs encryption classification analyses, submits commodity classification requests, oversees submission of license applications, and counsels on compliance with Department of Commerce encryption reporting requirements for Fortune 500 and Fortune 100 software and technology companies.
Regularly counsels large multinational software developers with respect to cross-border sales of software and the provision of cloud-based software services in compliance with U.S. export controls and sanctions laws, and regularly obtains Department of Commerce export licenses to support non-U.S. customer activity.
Developed global sanctions and export compliance programs for distributed database technology company, including procedures for determining applicability of U.S. encryption controls and for controlling technology and source code transfers.
Represented Fortune 100 information technology company in voluntary disclosure to the Department of Commerce for unauthorized exports of U.S. origin encryption restricted servers and related software to a number of countries across Asia.
Assisted international consulting and professional services company with classification of cyber security software solutions, with a focus on USML Category XIII(b) and encryption controls under the EAR, and drafted tailored compliance policies and training.
Prepared commodity classification request for forensic software company, and prepared related voluntary disclosure and waiver request to BIS.
Analyzed export classification and submitted commodity jurisdiction requests for defense simulation, training, and modeling software.
Analyzed export classification of multi-axis rate tables and prepared successful commodity classification request for reclassification of rate tables and related technology, and provided general export compliance counseling regarding exports of rates tables in compliance with EAR Part 744 restrictions.
Developed export compliance program for international methanol and petrochemical manufacturers with U.S. operations, and provided counseling on compliance with U.S. export and sanctions requirements.