Steven Brotherton

Steven Brotherton is the Principal, Global Export Controls & Sanctions Lead at KPMG LLP. He is located in the firm’s San Francisco, California office.

He counsels clients on export control laws and regulations, including compliance with the Export Administration Regulations (‘EAR’), International Traffic in Arms Regulations (‘ITAR’), and sanctions regulations administered by the Office of Foreign Assets Control (‘OFAC’). Prior to joining KPMG, Mr. Brotherton managed the Export Controls Practice Group for 15 years at AmLaw 100 firm Fragomen Worldwide and was the Practice Leader, Export Controls & Sanctions at Sandler, Travis & Rosenberg PA.

Mr. Brotherton advises a wide variety of clients on export control issues, ranging from Fortune 100 companies to mid-size companies and start-ups. Steven has developed and implemented export compliance programmes, conducted export control audits and assessments, led internal investigations and reviews, prepared export licences and agreements, and has successfully supported companies in connection with government investigations and enforcement actions. Mr. Brotherton is an appointed member of the U.S. Department of Commerce’s Regulations and Procedures Technical Advisory Committee, which advises the U.S. Department of Commerce on export control regulation and policy. He previously worked at The Boeing Company where he advised on licensing, compliance and other export control matters. Mr. Brotherton is a graduate of Auburn University (B.S.) and University of Alabama (J.D.) and is a member of the California Bar.

Representative experience

• Administered the implementation of precedent-setting ITAR consent agreements, including developing State Department mandated corrective actions.
• Serves as leading authority on ITAR jurisdictional matters and has obtained favourable EAR determinations on scores of commodity jurisdiction applications for technologies utilised in military and space end uses.
• Led State Department mandated ITAR audit of global electronics company, reviewing 25 key manufacturing locations in five countries.
• Developed and assisted with the implementation of a best-practice Technology Control Plan for a Fortune 50 company which, in turn, favourably resolved U.S. government investigation into the client’s deemed export compliance practices.
• Prepared export compliance programmes for clients ranging from emerging to Fortune 50 companies.
• Selected as one of 15 international participants in an international launch vehicle/satellite failure review and served as export control liaison.
• Negotiated U.S. government approval and Congressional certification for multi-billion dollar projects including, in several cases, Presidential approval for exports to China.
• Developed and executed strategic export licence planning and administration for U.S. military and space programmes.