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Dilan Wickrema

Associate | He/Him/His
Associate | He/Him/His
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Areas of Focus

Overview

Dilan Wickrema advises clients with respect to U.S. export controls, economic sanctions, the Committee on Foreign Investment in the United States (CFIUS), and related investigations. Dilan leverages his experience from his various roles at the intersection of international trade and national security in the federal government to ensure clients meet their cross-border transaction goals while complying with the applicable laws and regulations. Previously, Dilan served in the Directorate of Defense Trade Controls (DDTC), the Bureau of Industry and Security, and the International Trade Administration.

Most recently, while attending law school at night, Dilan was a Foreign Affairs Officer in the Regulatory and Multilateral Affairs Division of DDTC’s Office of Policy at the U.S. Department of State. At DDTC, Dilan was responsible for developing revisions to the ITAR, issuing authoritative interpretations of the ITAR (advisory opinions), supporting criminal prosecution of ITAR violations, CFIUS and export control integration efforts, and working with U.S. allies and partners to resolve defense trade matters of mutual concern.

While in law school, Dilan was the editor-in-chief of the National Security Law Journal.

Career & Education

    • Department of State
      Foreign Affairs Officer, Directorate of Defense Trade Controls, 2019–2023
    • Department of Commerce
      Analyst, Bureau of Industry and Security, 2018–2019
      Special Assistant to Under Secretary, International Trade Administration, 2018
      Analyst, International Trade Administration, 2016–2018
    • Department of State
      Foreign Affairs Officer, Directorate of Defense Trade Controls, 2019–2023
    • Department of Commerce
      Analyst, Bureau of Industry and Security, 2018–2019
      Special Assistant to Under Secretary, International Trade Administration, 2018
      Analyst, International Trade Administration, 2016–2018

    • George Mason University, J.D.
    • George Mason University, M.A.
    • George Mason University, B.A.
    • George Mason University, J.D.
    • George Mason University, M.A.
    • George Mason University, B.A.

    • District of Columbia
    • District of Columbia

Dilan 's Insights

Client Alert | 9 min read | 05.19.25

U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) formally rescinded the Framework for Artificial Intelligence Diffusion interim final rule published by the Biden Administration, on the basis that it stifled innovation, was overly complex, and undermined U.S. diplomatic relations....

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Representative Matters

Representative Government Experience

  • Advised U.S. and non-U.S. government agencies, private entities, and academic institutions on interpreting and ensuring compliance with U.S. export controls.
  • Drafted and implemented amendments to U.S. export control regulations and related regulatory guidance documents.
  • Assisted and advised the U.S. Department of Justice, DDTC’s Office of Compliance, and federal law enforcement agencies on prosecuting ITAR and Arms Export Control Act violations.
  • Conducted week-long seminars to train thousands of U.S. and non-U.S. stakeholders on U.S. export controls and the foreign military sales process.
  • Represented the U.S. Department of State and the U.S. Department of Commerce in bilateral and multilateral forums and at National Security Council Policy Coordination Committee meetings.
  • Led section 232 investigations on the effects of imports on national security.

Representative Firm Experience

  • Seconded to a Fortune 15 U.S. technology company to serve as in-house export control counsel, providing daily guidance on export control compliance and investigation matters.
  • Regularly counsels large multinational companies with respect to cross-border sales of controlled goods, technology, and U.S. person activities (defense services and brokering); use of export control exemptions; DDTC registration requirements; and preparation of license and agreement applications.
  • Provided strategic counseling to large defense contractor regarding changes to U.S. export control regulations.
  • Represented aerospace and defense contractor in an internal review of export control policies and procedures, and assisted in responding to DDTC Requests for Information regarding foreign person access to technical data.
  • Prepared third-party-transfer request for defense contractor seeking to transfer defense articles procured pursuant to the foreign military sales acquisition process.
  • Regularly conducts and supports internal investigations and disclosures to the Department of Commerce, Department of State, and the Office of Foreign Assets Control.
  • Developed export compliance program for a Fortune 500 company that furnishes defense services.
  • Regularly counsels entities on ITAR brokering registration and authorization requirements.
  • Assisted university in implementing an export-control and sanctions compliance program.
  • Regularly conducts buy-side due diligence regarding cross-border transaction risks, 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.
  • Provided counsel to former military personnel regarding compliance with foreign government employment restrictions.
  • Reviewed movie prior to release to ensure no controlled technology was recorded.
  • Obtained OFAC license for non-profit operating in embargoed countries.
  • Supported efforts to obtain CFIUS clearance for acquisitions of U.S. companies by non-U.S. companies.

Dilan 's Insights

Client Alert | 9 min read | 05.19.25

U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) formally rescinded the Framework for Artificial Intelligence Diffusion interim final rule published by the Biden Administration, on the basis that it stifled innovation, was overly complex, and undermined U.S. diplomatic relations....

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Recognition

  • Superior Honor Award, U.S. Department of State (2023)
  • Meritorious Honor Award, U.S. Department of State (2016, 2019 – 2022)
  • Gold Medal, U.S. Department of Commerce (2018)
  • Charles Meissner Award, U.S. International Trade Administration (2018)

Dilan 's Insights

Client Alert | 9 min read | 05.19.25

U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations

On May 13, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) formally rescinded the Framework for Artificial Intelligence Diffusion interim final rule published by the Biden Administration, on the basis that it stifled innovation, was overly complex, and undermined U.S. diplomatic relations....

View All Insights

Insights

Client Alert | 9 min read | 05.19.25

U.S. Department of Commerce Rescinds Biden Administration’s AI Diffusion Export Control Rule and Issues New Guidance on Huawei, Chips for AI Purposes, and Diligence Expectations

Speaking Engagement | 05.13.25

"International Trade Developments Affecting Contractors and their Supply Chains," OOPS 2025: Government Contractors Reacting and Adapting to the New Administration, Tyson's Corner, VA.

Blog Post | 05.09.25

U.S. Department of the Treasury to Establish Fast Track CFIUS Process for Foreign Investors

Blog Post | 05.08.25

DOJ Declines Prosecution of Company for Employee’s Unlawful Export

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