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.
Career & Education
- Department of State
Regulatory and Multilateral Affairs Analyst, Policy Office, Directorate of Defense Trade Controls (DDTC)
- Department of State
- 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)
Jana's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Blog Post | 04.22.24
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
Representative Matters
- 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 successfully obtained 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 software.
- 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.
Jana's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Blog Post | 04.22.24
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
Jana's Insights
Client Alert | 3 min read | 04.26.24
CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance
On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018. The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:
Blog Post | 04.22.24
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK