Chandler S. Leonard

Associate | She/Her/Hers

Overview

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

Chandler is a former compliance case officer with the Directorate of Defense Trade Controls (DDTC) at the U.S. Department of State, where she managed politically high-profile and complex investigations of ITAR violations involving companies in a range of industries, from large defense contractors to small companies in the emerging technology field. While at DDTC, she oversaw a multinational conglomerate’s efforts to satisfy the requirements of an administrative settlement agreement and bring the consent agreement to conclusion. Chandler also participated in complicated regulatory and policy matters in the advisory opinion process, including issues related to defense services, mergers and acquisitions in foreign countries’ defense industry, and cloud computing. She also engaged in DDTC liaison with law enforcement agencies, federal prosecutors, and the intelligence community.

Chandler is most recently a former sanctions compliance officer with the Office of Foreign Assets Control (OFAC) at the U.S. Treasury Department, where she lead complex and high-profile investigations of apparent sanctions violators within the regulated financial sector, including U.S. financial institutions and foreign financial institutions. Chandler also brings in-house experience with navigating complex export control issues, including internal investigations and audits, for a large defense contractor.

Career & Education

    • Department of State
      Senior Compliance Specialist, Directorate of Defense Trade Controls, 20162018
    • Department of the Treasury
      Sanctions Compliance Officer, Office of Foreign Assets Control, 20182020
    • Department of State
      Senior Compliance Specialist, Directorate of Defense Trade Controls, 20162018
    • Department of the Treasury
      Sanctions Compliance Officer, Office of Foreign Assets Control, 20182020
    • Midwestern State University, B.A., magna cum laude, international studies and political science, 2008
    • George Mason University School of Law, J.D., 2013
    • Midwestern State University, B.A., magna cum laude, international studies and political science, 2008
    • George Mason University School of Law, J.D., 2013
    • District of Columbia
    • Maryland
    • District of Columbia
    • Maryland

Chandler's Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....

Chandler's Insights

Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....