Law Practice Focusing On
Economic Sanctions, Export Controls, Anti-Terrorism/FSIA Litigation &
National Security Legal Matters
Steven W. Pelak
Independent Representation & Counsel
Steve focuses his practice on civil and criminal enforcement proceedings, corporate and individual compliance matters, and the representation of U.S. victims of state sponsored terrorism.
With more than 35 years of experience, he provides clients with sound counsel and advocacy on administrative investigations and enforcement actions, grand jury investigations, and criminal prosecutions, as well as internal corporate compliance matters.
Relevant Experience
Steve has significant experience as a federal prosecutor and in private practice handling and supervising the investigation, prosecution, and defense of export controls, sanctions, national security, white collar fraud, public and union corruption, terrorism, and other federal offenses. He counsels and represents individuals and corporate clients in federal administrative and criminal inquiries, investigations, and enforcement actions. Steve's long and deep experience has been recognized by Chambers Global and Chambers USA rankings in Export Controls & Economic Sanctions.
Steve assists clients with internal corporate compliance and due diligence efforts with regard to export controls, sanctions, anti-corruption, anti-money laundering, national security, and other statutes and regulations, including the Arms Export Control Act/International Traffic in Arms Regulations (ITAR); the Export Administration Regulations (EAR); the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) sanctions programs; the Foreign Corrupt Practices Act (FCPA); the Committee on Foreign Investment in the United States (CFIUS); the Foreign Agents Registration Act (FARA); anti-money laundering (AML) laws and other federal regulatory schemes. From 2018 through 2024, the Assistant Secretary of Political-Military Affairs, U.S. Department of State, appointed Steve to serve as a member of the Defense Trade Advisory Group (DTAG). DTAG advises the Department of State on its administration and enforcement of the ITAR and its regulation of international defense sales to protect and advance the foreign policy and national security interests of the United States, while reducing impediments to legitimate exports.
Prior to opening his own law office and retiring from “big-law firm” practice, Steve was a partner in the Washington, D.C. office of Holland & Hart from June 2013 until June 2023.
For 25 years before joining Holland & Hart, Steve served as a federal prosecutor in several roles within the U.S. Department of Justice and U.S. Attorney’s Office for the District of Columbia. During the years from 2007 until 2013, Steve served as the Justice Department's first National Coordinator for Export Controls/Sanctions Enforcement as well as the Principal Deputy Chief and then the Acting Chief of the Counterespionage Section (CES) of the National Security Division. CES is now titled the Counterintelligence and Export Control Section.
In those roles, Steve directed a national program of federal prosecutors and investigators to enhance and increase the U.S. government's ability to investigate and prosecute export control and sanctions violations. Leading the Justice Department's export controls/sanctions enforcement activities and public outreach efforts, Steve has a deep understanding of the U.S. government's policies and enforcement of national security trade laws and regulations, including the current and emerging policies and priorities of federal administrative and law enforcement agencies.
In addition, Steve served for 18 years as an Assistant United States Attorney in the U.S. Attorney's Office for the District of Columbia in a wide variety of capacities. He handled numerous federal investigations and prosecutions involving fraud, bribery, export control and sanctions offenses, public corruption, labor union embezzlement and corruption, national security offenses, and overseas terrorist acts against U.S. citizens. He served as lead counsel on dozens of jury trials and appellate arguments before the U.S. Court of Appeals for the District of Columbia Circuit, the U.S. District Court for the District of Columbia, the Court of Appeals for the District of Columbia, and the Superior Court of the District of Columbia.
Prior to his service as a federal prosecutor, Steve served as an associate with the firms of Hughes Hubbard & Reed and Arnold & Porter and as a judicial law clerk for Chief Judge Douglas W. Hillman of the U.S. District Court for the Western District of Michigan.
Steve's experience in export controls, sanctions, FCPA, FARA, CFIUS, AML, and public corruption matters allows his clients a unique and wide perspective on a range of important U.S. Government regulatory, investigative, and enforcement initiatives and actions.
Results
Opati v. Republic of Sudan, 590 U.S. 418 (2020) - Civil action resulting in unanimous opinion by the Supreme Court of the United States vacating Court of Appeals and reinstating punitive damages awarded to more than 150 U.S. Government employees killed and injured in August 1998 bombings of the U.S. Embassies in Nairobi, Kenya and Dar es Salaam, Tanzania
Fritz v. Islamic Republic of Iran and Islamic Revolutionary Guards Corps, 320 F.Supp.3d 48 (D.D.C. 2018)- Civil action resulting in bench trial and final judgment against the Government of Iran and IRGC for the extrajudicial killings, torture, and hostage taking of four members of the U.S. Army in Iraq
In re Rescission and Removal of the September 2016 OFAC Designations of PacNet Services, 12 individuals, and more than 30 companies - Petition to the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) resulting in the rescission and removal of OFAC's designations of PacNet Services, subsidiary companies, and 12 individuals and an interpleader complaint filed against the U.S. Government and others
Defense Trade, Manufacturing, Engineering, and Technology Public and Private Companies - Internal Investigations, Advice and Counsel, Representation before the U.S. Government, and Defense on matters involving the Arms Export Control Act/International Traffic in Arms Regulations {ITAR), Export Administration Regulations (EAR), OFAC Sanctions, Foreign Corrupt Practices Act (FCPA), Committee on Foreign Investment in the United States (CFIUS), Foreign Agents Registration Act (FARA), and related national security and government inquiries, investigations, and enforcement actions
U.S. v. ABN AMRO Bank - Investigation and prosecution of an international bank relating to OFAC sanctions violations
U.S. v. West, et al. - Investigation and prosecution of the President of the International Association of Iron Workers and other national union officials for embezzlement and related fraud offenses
In re Missile Technology Transfer to China - Investigation of export control violations arising from alleged transfer of missile or space launch vehicle technology by U.S. companies Space System/Loral and Hughes Space and Communications
U.S. v. United Technologies Corp. and Pratt & Whitney Canada Corp. - Supervision of the investigation and prosecution of the unlawful export of technical data to China relating to engine software for attack helicopters
U.S. v. ITT Corp. - Supervision of the investigation and prosecution of the unlawful export of technical data to China relating to night vision equipment
U.S. v. BAE Systems - Supervision of the investigation and prosecution of a multinational defense contractor arising from a conspiracy to make false statements regarding foreign payments in relation to the sale of defense articles required to be disclosed to the State Department under the AECA/ITAR and false statements about its Foreign Corrupt Practices Act compliance program
U.S. v. Brown, et. al. - Investigation and prosecution of 12 officers of the Metropolitan Police Department for bribery, public corruption, and conspiracy offenses (United States v. Washington, 106 F.3d 983 (D.C. Cir.), cert. denied, 522 U.S. 984 (1997))
In re Certified Public Accountants - Investigation and prosecution of two Certified Public Accountants and outside auditors of an ERISA fund and the International Association of Iron Workers for participation in a scheme to cover up embezzlement and to file false financial reports
In re Ruby Ridge - Investigation and prosecution of obstruction of justice and criminal conduct by FBI Headquarters Officials
In re Embezzlement from the Public Defender Service - Investigation and Prosecution of the Chief Financial Officer of a local governmental agency
U.S. v. Stowe - Investigation and prosecution of an official of the Metropolitan Police Department for extortion, fraud, and theft
Publications
11/21/2023 | The Hill
10/06/2022 | International Compliance Blog
The Staff of the U.S.-China Economic and Security Review Commission Warns Against the CCP's LOGINK
04/16/2021 | International Compliance Blog
President Biden Gets Tough on Russia with New Executive Order
12/24/2020 | International Compliance Blog
Commerce Names More than 100 Chinese and Russian to Inaugural MEU List
12/18/2020 | International Compliance Blog
03/11/2020 | WorldECR
3D Printing/Blockchain Merger: A potential supply chain security and export control compliance tool?
12/20/2019 | International Compliance Blog
11/27/2019 | International Compliance Blog
OFAC: Sanctions Compliance Provisions in Lease Agreements Alone May Be Insufficient
10/22/2019 | International Compliance Blog
10/09/2019 | International Compliance Blog
OFAC Redefines the Term "Significant Transnational Criminal Organization Broadening Its Reach
09/12/2019 | International Compliance Blog
Trump Administration Tightens Cuba Sanctions, Eliminates "U-Turn" Authorization
08/07/2019 | International Compliance Blog
07/19/2019 | Holland & Hart News Update
OFAC Expands Sanctions-Related Rejected Transaction Reporting Requirements
02/21/2019 | Holland & Hart News Update
Export Control Laws Not a Blank Check to Exclude Job Applicants
10/23/2018 | Holland & Hart News Update
11/01/2017 | World ECR
03/01/2016 | The Export Practitioner
02/20/2014 | Corporate Governance Advisor
10/01/2013 | Law360
Recognition
- 2017-2023 Chambers Global, USA, International Trade: Export Controls & Economic Sanctions
- 2016-2022 Chambers USA, International Trade: Export Controls & Economic Sanctions, Nationwide
- 2012 National Counterintelligence Executive's Award for Counterintelligence Investigations and Prosecutions for participation in an export control investigation and prosecution relating to China
- 2011 U.S. Department of Commerce Assistant Secretary's Award for Export Enforcement
- 2010 Attorney General's Award for the Advancement of the National Security relating to an Iranian sanctions prosecution involving the national security
- 2009-2013 Senior Executive Service (SES), U.S. Department of Justice
- 2001-2007 District Coordinator, Anti-Terrorism Advisory Council (ATAC)
- 1999-2007 Senior Litigation Counsel
- 1998 Director's Award for Criminal Trial Litigation, Executive Office of U.S. Attorneys
- Numerous Special Achievement and Recognition Awards from the U.S. Attorney for the District of Columbia and Federal Law Enforcement Agencies
Professional and Civic Affiliations
- Defense Trade Advisory Group (DTAG) of the U.S. Department of State, Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, 2018-2024
- ABA International Law Section, National Security Committee Steering Group
- Society for International Affairs
- American Society of International Law
- Association of Assistant United States Attorneys, Washington, D.C.
- Thurgood Marshall American Inn of Court, Member (former)
- U.S. Government Senior Executive Service (former)
- Board Member and President, Highlands Swim & Tennis Club (former)
Education
-
University of Michigan Law School, J.D., 1985, cum laude
-
Kalamazoo College, Economics, cum laude, Phi Beta Kappa
Bar Admission
- District of Columbia
Court Admissions
- U.S. Supreme Court
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Court of Appeals for the Second Circuit
- U.S. District Court for the District of Columbia
- District of Columbia Court of Appeals, Washington, D.C.
- Superior Court of the District of Columbia
Practices
- Export Controls, Economic Sanctions, and FARA
- Government Investigations and White-Collar Defense
- FCPA and Anti-Corruption
- CFIUS and National Security International Services
- Anti-Terrorism/Foreign Sovereign Immunities Act
Services
- Representation
- Counseling
- Compliance Advice
- Enforcement Actions
- Internal Investigations
- Delisting Petitions
- Independent Monitor
- Legal Consultant and Review
Let’s Connect
Steven W. Pelak
Independent Representation & Counsel
1717 Pennsylvania Avenue, N.W.
Suite 650
Washington, D.C. 20006