ACSS Export Controls

Task Force


ACSS has a large global membership and includes professionals who do not only work in sanctions but also in export controls. These two areas are strongly intertwined and most of our members working in the sanctions field are also interested in receiving and exchanging information on export controls.

Several export control regimes impact the work of ACSS members. Of particular interest are the U.S. Export Control Regulations “ITAR” and “EAR”, the EU Dual-Use Regulation and the UK Export Control Act, but also newer regimes such as Chinese export controls.


The Taskforce is responsible for providing the highest level of member and industry perspective in guiding ACSS programs and services. Your leadership will be a key element in keeping ACSS on the cutting edge in providing state-of-the-art benefits related to export control to our members. The mission of the Taskforce is to advise ACSS and its members on global export control practices and guidance, and to promote ACSS as the premier provider of export control training services to its members.

The Export Controls Task Force was created to review best practices regarding export control rules and processes. Specifically, the Task Force should:

  • provide guidance to ACSS on what additional products/courses, services ACSS should provide or create to fulfil the needs of the members on this topic
  • identify commercial best practices of EU, US and other export control regimes and help organize webinars or sessions on this topic or create resources for the ACSS membership
  • Develop cooperation and conduct outreach on behalf of ACSS with government agencies, international organizations, and international working groups on export control (e.g. Dual Use Business europe group, Chaudfontaine group, ENEF);


Stephen Wilcox

Chair Taskforce | Managing Director | Forensic & Litigation Consulting

Stephen Wilcox specializes in U.S. and foreign export controls and sanctions matters, including conducting corporate trade compliance investigations and audits, due diligence advising, the development of Internal Compliance Program (ICPs), Voluntary Self-Disclosures (VSDs) advisory, and restricted party list removal support services.

Dennis H. Cavanaugh

Intelligence Officer

Dennis H. Cavanaugh is an attorney and former CIA intelligence officer with over 30 years of experience representing national and international clients in the areas of intellectual property, international trade, government regulatory compliance, international commercial transactions, technology transfer and international litigation. In the area of export controls and technology transfer, Mr. Cavanaugh has assisted companies in compliance with the laws and regulations of all of the relevant U.S. agencies with jurisdiction over exports of products and technology. He has worked with numerous products and technologies and has advised clients on compliance with various embargo and sanctions programs.

Bryce WU

Trade Compliance Director
Dell Technologies

Joined to Dell Technologies in Jan 2017, Bryce has been the Asia Pacific Trade Compliance Director managing a team of 40+ trade compliance professionals across the region, covering all aspect of trade compliance for the region. Prior to this role, Bryce worked in United Technologies Corporation as the Asia International Trade Compliance (ITC) Director for the Building & Industrial System (BIS), who was the first full time ITC resource in APAC region. Bryce was also the first full time trade compliance profession in Honeywell for its Automation and Control Solutions (ACS) in Asia, in where he created & stabilized the Asia Pacific trade compliance organization. Bryce has been recognized as one of the “first generation” in-house trade compliance practitioners in China who started his full-time trade compliance role 15+ years ago with prior logistics and supply chain working experience.

Ornella Belfiori

Lawyer | DLA Piper

Ornella Belfiori is a Lawyer within the DLA Piper’s White Collar Crime, Investigations & Compliance practice. Since joining the Firm, Ornella has provided practical, day-to-day advice on economic sanctions and export controls issues of all varieties, also pursuant to relevant Italian legislation. Ornella assists multinational clients, inter alia, in the design and implementation of tailored trade compliance programs and in relation to custom related product classifications, as well as in liaising with competent Authorities for the purpose of obtaining licenses/authorizations. Ornella’s practice also focuses on white collar defence, with deep experience in conducting cross-border fraud and anti-corruption internal investigations. Ornella advises multinational companies on compliance and anti-corruption matters, pursuant to Italian legislation and international best practices (FCPA, UKBA), and has experience in developing compliance programs pursuant to Legislative Decree 231/2001.

Alessandro Guaiana

Sanctions Compliance Officer | European Investment Bank (EIB)

Alessandro Guaiana is an Italian qualified lawyer and certified fraud examiner working as a sanction compliance officer at the European Investment Bank based in Luxembourg. Alessandro holds a variety of expertise in sanction and export control regulations, having served in different sectors: legal, advisory, fraud and investigation services, oil and gas and financial. Alessandro worked, among others, for Studio Legale Padovan, EY, ENI and, today, the EIB, advising on a daily basis on global sanctions and export control compliance issues.

Ben Gross

Trade Counsel | Intel Corporation

Ben Gross is a trade compliance professional with a concentrated focus on global trade regulations, export classification, government reporting, and auditing. Ben has developed and supported international trade compliance programs for businesses with a global footprint. He is currently Trade Counsel at Intel Corporation, is an Associate Faculty member at Sandra Day O’Connor College of Law, and has served in various legal and advisory support capacities for Assent, EY, Honeywell International Inc., and Microchip Technology Inc.

Thomas Andrukonis

Senior Director, Export Controls, Sanctions & Trade | FTI Consulting

Thomas Andrukonis is a Senior Director in the Export Controls, Sanctions, & Trade (ECST) practice at FTI Consulting. He specializes in U.S. and foreign export controls and sanctions matters, including license application development strategies, export control investigation support, internal compliance program development, conducting risk and threat based assessments, end-use monitoring advisory services (Post Shipment Verifications and Pre-License Checks), Voluntary Self-Disclosure submission support, General Prohibition 10 advisory, delisting support services and the development of enhanced due diligence programs. He further specializes in Technology Control Plan support, in countering illicit Technology Transfer, supporting the protection of Intellectual Property, preventing compromise of Critical Program Information and emerging technologies.

Keith Huffman

Chief Legal Counsel, Export Control US (Global) | SAP

Keith Huffman is Chief Legal Counsel, Export Control US (Global) at SAP and based in the UK. In this role he serves as legal advisor on U.S. export control and sanctions laws applicable to SAP’s global activities. His responsibilities include adopting and implementing SAP global corporate policies and strategies, helping manage SAP’s global export control and sanctions compliance program, training stakeholders on export control and sanctions requirements, collaborating with SAP legal teams on contract negotiations and advising operations and compliance teams regarding U.S. export control and sanctions laws requirements. Previously, Mr. Huffman was in private practice in London and Washington, D.C. for international law firms, and prior to this he worked in the U.S. Government, focusing on a wide array of foreign policy and international trade matters.

Mandy NG

Sanctions Compliance Professional

Todd Willis

Global Trade Advisor | Caterpillar, Inc.

Following a military and federal service career of over 25 years, Mr. Willis accepted the newly established role of Global Trade Advisor at Caterpillar, Inc. In this role, he is responsible for supporting the strategic development, delivery and execution of international trade to support the enterprise. In addition, Mr. Willis works to enhance and manage relationships with U.S. and foreign government law enforcement and regulatory agencies. Mr. Willis has a Master’s of Science degree in National Security from NDU, Eisenhower School. He also graduated cum laude with an MBA from California State University, Hayward and has a Political Economics from the University of the Pacific.

Webinar Recording June 09 - Understanding US and EU Encryption Controls
Webinar Recording July 14 - Interplay between US agencies on Sanctions and Export Controls