Export Compliance Solutions & Consulting (ECS)
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Our most recent posts
November 1, 2024Export Regulatory and Policy Update Roundup: Fall 2024
State and Commerce Departments Propose Spacecraft Control Changes
August 26, 2024
New DDTC Rules: AUKUS Exemption, Defense Services Proposal, and Non-Exports
July 12, 2024
Commerce Updates: Firearms, Countries, and Turkey Antiboycott Advisory
May 3, 2024
Following Commerce/BIS, State/DDTC Proposes AUKUS Exemption!
Export Compliance Solutions & Consulting Team
Suzanne Palmer founded Export Compliance Solutions (ECS) in 2003 to meet industry compliance needs related to training, audits of the ITAR, EAR and OFAC regulations and jurisdictional analysis. ECS has used the experience in these areas to assist companies establish export compliance programs to minimize legal and regulatory risks. Ms. Palmer has served the industry in numerous capacities to include the Defense Trade Advisory Group (DTAG) that interacts with the Departments of State and Defense on export compliance issues. Ms. Palmer also has experience as a Special Compliance Officer (SCO) appointed by the State Department for a company under scrutiny in a Consent Agreement as well as serving and has served on a SCO Team. She has also been approved as an outside auditor by the State Department’s Defense Trade Compliance (DTTC) for companies operating under a Consent Agreement. Ms. Palmer’s particular focus is building compliance programs for companies, conducting audits of ITAR and EAR compliance, and performing training for ITAR and EAR compliance at the Basic, Intermediate and Advanced levels.
Prior to founding the company, Ms. Palmer worked as Manager of Export Compliance for the Space Department at the Johns Hopkins University Applied Physics Laboratory. As Manager of Compliance, Ms. Palmer performed all the export training for the Space Department Program Managers, created policy directives and procedures, participated in and conducted all follow-up for export audits, classified products and technology, drafted and administered export licenses and agreements and acted as the U.S. Government liaison for the Space Department.
Previous to this position, Ms. Palmer worked as the Export Manager for the Electronic Systems division of Northrop Grumman in Linthicum, Maryland. During her tenure, she witnessed the acquisition of Litton Corporation and managed the export activity of the existing and incoming business units. Export training, overseeing license transactions, ITAR exemption use and creating procedures for technical paper review were just a few of her responsibilities.
Before joining the defense industry, Ms. Palmer worked in the U.S. Department of State and served in a variety of positions:
- Bureau of Non Proliferation (NP) establishing a NATO WMD Center and contributed regularly to substantive debate on critical proliferation problems within the NATO Senior Political-Military Group on Proliferation.
- Arms Control & Disarmament Agency (ACDA) working on conventional arms control, nonproliferation, Weapons of Mass Destruction (WMD) and regional arms control.
- Office of Defense Trade Controls (ODTC) overseeing licensing for various commodities.
- Office of Defense Trade Policy contributing to the ITAR USML review, drafted policy papers for the Defense Trade Advisory Group (DTAG) and assisted in the formulation of defense trade policy toward the former Soviet Union.
Ms. Palmer holds two Bachelor’s degrees from Mary Washington College in International Affairs and French. She also earned a Masters degree from American University in International Affairs and has taken courses toward a Masters of Business Administration at Johns Hopkins University. Ms. Palmer is married to Scott Miller and they have two children, three animals and a couple of old boats at their home in Annapolis, MD.
Mal Zerden was a Supervisory Defense Controls Analyst and Division Chief of the Aircraft Division in the Department of State’s Directorate of Defense Trade Controls (DDTC). He had 27 years experience in State/DDTC and supervised the work of licensing analysts and ensured that they were properly trained. Mr. Zerden’s division was responsible for licensing defense articles and related technical data for military aircraft. He also assisted industry in resolving problems that arose with pending cases and provided guidance on complex licensing scenarios. He worked closely with principal action officers at other U.S. Government agencies involved in the review and coordination of licensing activities and arms export policy as well as foreign governments and U.S. industry about the regulations and State/DDTC policies and procedures. He participated in numerous export conferences and has spoken on many topics related to defense trade and the ITAR.
Mr. Zerden started at State/DDTC as a licensing officer covering ships, military electronics and toxicological agents and equipment. He subsequently became the Branch Chief responsible for aircraft, missiles, space, ships, firearms and ammunition, toxicological agents and other USML articles. During his tenure, he either licensed or supervised the licensing of almost every category covered by the USML. He reviewed the work of other licensing officers and military officers, and signed off on Commodity Jurisdiction requests, Technical Assistance Agreements, Manufacturing License Agreements and Distribution Agreements. He provided guidance to Customs and Border Control (CBP) and Immigration Customs and Enforcement (ICE) concerning specific articles that were covered by the U.S. Munitions List. He interpreted the regulations for CBP and ICE, trained officers from those organizations and testified at trials that involved violations of the Arms Export Control Act (AECA).
Prior to his work at DDTC, Mr. Zerden worked in the Consular Affairs Bureau at the State Department serving as a Passport Officer and as a Management Analyst.
Mr. Zerden received a BA in Secondary Social Studies from the University of New York, College at Cortland. He received an MA in International Relations with an emphasis on U.S. Foreign Policy from American University in Washington, D.C.
Lisa Bencivenga is a consultant with thirty years of experience in export/import licensing and compliance activities. She has had the leading role in developing and implementing internal compliance programs, providing regulatory guidance, instituting license databases, conducting jurisdiction and classification determinations, training personnel at all corporate levels, conducting audits requested by clients and/or directed by the U.S. Department of State, coordinating investigations and working closely with legal departments while administering the full spectrum of corporate international export/import activities. She has experience in various complex issues (e.g., unmanned aerial vehicles, space-related activities, foreign government licensing/compliance strategies) including obtaining and implementing complex licensing arrangements and meetings/briefings to key U.S. government officials to support program management business plans. As a result of her employment with Orbital Sciences Corp. (now Northrop Grumman Innovation Systems), The Boeing Company, and owning her own consulting company since 2004, she has experience in developing and implementing licensing strategy plans within complex U.S. export control policies.
Since establishing her consulting business, Lisa Bencivenga, LLC, she has represented over 150 U.S. and foreign companies with the U.S. Government on a wide range of regulatory and policy-related matters working closely with the U.S. Departments of State, Defense, Commerce, Treasury, and Justice. Her experience includes assisting companies in Argentina, Australia, Austria, Brazil, Canada, Germany, Italy, Japan, Mexico, Singapore, and the United Kingdom by working directly at their facilities providing auditing and training services and/or various compliance requirements such as obtaining required U.S. export/re-export/import authorizations. She has also trained foreign military personnel in understanding the complex issues surrounding the movement of both commercial and military goods into and out of the United States to include developing processes to ensure jurisdiction and classifications are conducted in accordance with the required methodology. She has been approved by the U.S. Department of State to conduct directed audits and monitoring activities for companies operating within the requirements of Consent Agreements. She is also a Sr. Advisor for Alpha Omega Consulting Group since November 2019.
She was an officer and member of the Board of Directors for two 2-year terms, including a term as Director of Planning and Education, of the Society for International Affairs, a Washington D.C.-based government-industry, non-profit educational organization concerned with trade export control matters.
As a member of the U.S. Department of State’s Bureau of Political-Military Affairs’ Defense Trade Advisory Group (DTAG) from 2008-2016, Lisa advised the Bureau on various regulatory and policy defense trade issues. Members are appointed by the Assistant Secretary of State for Political-Military Affairs.
She has been a speaker for Society for International Affairs, Export Compliance Solutions, Association of University Export Control Officers, and other various organizations. She holds a B.S. in Business Administration from National-Louis University.
Karma E. Ruiz, Licensed Customs Broker, is the founder and President of World Wise Consulting Inc., a firm specializing in Customs and FDA compliance, duty audits, drawbacks, compliance programs, security and logistics management for both TSA and C-TPAT. Currently in charge of a consulting company, she is active on the board of directors with the Florida Customs Brokers and Forwarders Association and participates in all quarterly meetings with Customs and Border Protection to ensure that the trade community’s voice is heard on all regulation matters. Ms. Ruiz’s background includes post entry work, comprehensive duty audits, drawback program set-up, C-TPAT certifications for several large importers and forwarders, logistics management, and US Customs issue resolution.
Ms. Ruiz brings significant experience in working with regulating entities and the development of processes for clients to understand and operate within those guidelines. In addition to the development and implementation of comprehensive compliance programs, Ms. Ruiz has audited several companies’ operational procedures under these programs, has significantly reduced their exposure and has mitigated penalties after developing integrated points of verification for the prevention of additional violations. Ms. Ruiz has traveled to Europe, Central America, South America, as well as extensively in North America in these endeavors.
Chip is a specialist in auditing, training, strategic market and product planning, systems processes, workflow optimization, and the integration/implementation of new business systems. A graduate of the University of Virginia with a degree in business, Chip has acquired over thirty years of work experience in both the federal and private sectors, helping organizations reach their business and revenue goals by training staff in value-driven strategies and tactics to implement new programs and systems. He has conducted hundreds of initial audits to identify root problems, and then worked closely with clients to devise solutions that were achievable within their organizational cultures.
Chip conducted his first formal training class in 1978 for Savin Corporation. Since joining ECS in 2007, he has led more than 100 ITAR training sessions. He has performed ITAR and EAR audits and gap analyses at manufacturing plants, organizations, and universities throughout the United States.
Because of his familiarity with management strategies across a wide range of industries and his demonstrated track record of success in helping organizations attain their goals in today’s turbulent business environment, Chip has gained a solid reputation among ECS clients as a savvy instructor and knowledgeable mentor who is able to inspire and motivate employees to accept change.
Chip and his wife Karen reside in Fredericksburg, Virginia. He is passionate about the water, spending much of his spare time at his waterfront land in Virginia’s Northern Neck. Their son has a music degree from Bath Spa University in the U.K., performs with the Metropolitan Opera, and is an aspiring artist in Manhattan.
Paul G. Lasko joined Westinghouse in 1985 following a 25-year career in the U. S. Navy. While in the U. S. Navy, Mr. Lasko served in the Republic of Vietnam as Second Coastal Zone Intelligence Officer; Executive Assistant to the Director of Naval Intelligence; and Commanding Officer of the Naval & Marine Corps Intelligence Training Center. Mr. Lasko served in the USSR as Assistant Naval and Air Attach. He was also a founder of the Atlantic Fleet Tactical Training Group. His afloat duties included surface ships and Carrier Group Staffs. He retired in 1985 with the rank of Captain. His personal decorations include the Legion of Merit, Bronze Star with Combat V, Defense and Naval Meritorious Service Medal, four Air Medals, Navy Commendation Medal with Combat V, and the Vietnamese Cross of Gallantry with Gold Star.
Upon joining Westinghouse in 1985, Mr. Lasko founded and subsequently managed the Westinghouse Technology Assessment Laboratory (TAL) that is responsible for assessing various technologies. Mr. Lasko received the George Westinghouse Signature Award for his leadership in establishing the TAL as a successful new business operation.
Mr. Lasko assumed duties as Oceanic Division International Marketing Manager in 1988. In 1993, Mr. Lasko was Oceanic Divisions recipient of the Presidents Quality Achievement Award for Management.
Mr. Lasko joined the Northrop Grumman Electronic Sensors and Systems International Company in 1996 as Manager, Ship Systems International where he provided strategic and marketing leadership to identify and win international naval Business. He retired in 1998 and formed The Lasko Corporation to provide management consulting services.
The Lasko Corporations contracts include providing strategic and tactical advice to a major defense contractor for an international Naval procurement; providing international business classroom instruction for the Universities of Baltimore and Maryland; and developing new business strategies for a Cambridge, Massachusetts technology company. In 2003, Mr. Lasko was elected to the Board of Directors of Maryland Technology Corporation where is a Senior Advisor.
Mr. Lasko graduated from the University of Connecticut with a degree in economics and received an MBA from Georgetown University.
Yraida Bretz, better known as Edie, is Vice President of Priority One International, a US Customs Broker and Freight Forwarding company headquartered in Orlando, Florida.
Mrs. Bretz began her career with Priority One in 1989 as an import specialist, and from that time she has played a crucial role in the research and development of the companys international logistics and compliance programs. Edies knowledge in international trade goes well beyond the US border.
Mrs. Bretz and her husband, Paul Bretz, are the owners of Priority One International. It is their goal to provide a superior level of exceptional service in both freight forwarding and Customs brokerage far exceeding that of their competitors.
In order to stay abreast of the regulations affecting international trade, Edie regularly attends import and export seminars throughout the year such as SIA conferences, BIS Updates and workshops, and Customs seminars relating to the compliance of international trade.
Niclas Dahlvang was an analyst for the Department of State's Office of Defense Trade Controls Licensing for seven years. He worked in DDTC’s Space and Missile Technology and the Electronic Systems Divisions which were responsible for licensing defense articles for missiles, spacecraft, explosives, chem-bio defense equipment, and military electronics for a wide range of platforms and systems. He reviewed thousands of requests including export license applications, retransfer requests, and technical assistance agreements exceeding $28 billion for 165 countries. As OIF/OEF Expedite Officer, he managed the Electronic Systems Division's licenses for forces deployed in Iraq and Afghanistan.
With ECS, Mr. Dahlvang helps businesses navigate export regulations, determine export classifications of products, and prepare export license applications, technical assistance agreements, voluntary disclosures, and other requests subject to the jurisdiction of the Departments of State (ITAR, USML), Commerce (EAR, CCL), and Treasury (OFAC). He also writes export compliance updates for the ECS blog, edits export compliance policy & procedure manuals, and assists with audits and risk assessments.
Mr. Dahlvang holds a B.S. in Computer Science and a B.A. in History from Gonzaga University and a J.D. from the Gonzaga University School of Law. During law school, he attended the Institute on World Legal Problems in Innsbruck, Austria and was an Associate Editor of the Gonzaga Law Review. He is a member of the District of Columbia Bar, the South Dakota State Bar, and the South Dakota State Bar Administrative Law Committee. His law review article, "Thieves, Robbers, & Terrorists: Piracy in the 21st Century," was published in the Spring 2006 issue of the Regent Journal of International Law. He has served on Society for International Affairs (SIA) Task Forces updating SIA’s ITAR Voluntary Disclosure Handbook and Mergers, Acquisitions & Divestitures Handbook.
He lives on the South Dakota prairie, on the ridge where the West commences, with his wife, children, and a variety of four-legged animals.
Melva is an experienced attorney with over thirty years of proven in-house success in developing and implementing legal and business strategies to achieve client goals. Her areas of expertise include domestic and international business, compliance, aviation transactions, contract review and negotiations, and insurance and risk management.
Following a lengthy career as head of the legal department for the U.S. subsidiary of an Italian aircraft manufacturer, Melva opened her law practice in 2018. The practice is focused on providing practical legal advice to entrepreneurs and businesses of all sizes.
Her compliance audit experience includes evaluation of organizations’ systems, policies and practices to ensure they satisfy U.S. laws and regulations related to export control and economic and trade sanctions as well as review of curative measures implemented to address prior compliance issues.
Recent compliance audit work includes teaming with Export Compliance Solutions to perform an audit of CAE, a global provider of aircraft simulators and training services, in relation to U.S. economic sanctions administered by OFAC.
Detailed information regarding the firm’s practice areas can be found at www.mexnerlaw.com.
Melva is a graduate of Saint Joseph's University and Temple University School of Law. She is admitted to the bar in Pennsylvania and New Jersey.
Brent Jones, Trade Compliance Manager, Lisa Bencivenga, LLC, and has twenty years of experience in export/import licensing and compliance activities. His experience includes working in industry for General Dynamics SATCOM Technologies, Inc., Esterline Technologies, General Dynamics Land Systems, and working as an export consultant to include working for Lisa Bencivenga, LLC, since 2018.
As an Empowered Official, Brent has held the leading roles in various positions to ensure compliance to applicable import/export and domestic trade laws and regulations, including, but not limited to Arms Export Control Act and the International Traffic in Arms Regulations (ITAR), Export Administration Act and the Export Administration Regulations (EAR), Gun Control Act, National Firearms Act, Organized Crime Control Act and the implementing regulations of the US Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives, National Security Act, National Industrial Security Program Operating Manual (NISPOM) and the implementing regulations of the US Department of Defense, Defense Security Service. He has been involved in implement licensing specific policy/requirements by the organizations (arrangements, procedures, systems, etc.), interpret and explain compliance/licensing requirements and regulations, assist in resolving issues, and provide guidance and clarifications and suggest alternative courses of action to include developing and implementing import/export authorization strategies.
As a manager he was responsible for the development and processing of import/export authorizations by his Licensing Team, prepare and submit authorizations requests in accordance with regulatory requirements and business objectives, including the preparation of general correspondences (retransfer requests, advisory opinions, proviso reconsiderations, etc.), review of applications to ensure they meet business objectives and the evolving requirements published in the Federal Register and/or US Department of State Agreements Guidelines, lead and executed key projects related to Trade Compliance, to include amending authorizations pursuant to Export Control Reform, and lead the review in Jurisdiction and Classification determinations with Engineering Departments to include the development of procedures and detailed processes.
Brent has been responsible for training, motivating and supervising export compliance staff. In addition he has lead, trained and mentored direct reports and senior management on their responsibilities in an effort to increase the “Culture of Compliance” within each company.
Detailed information regarding the firm’s practice areas can be found at www.mexnerlaw.com.
Brent was a member of the U.S. Department of Commerce’s Bureau of Industry and Security Information Technical Advisor Committee (ISTAC) from 2012-2016 and advised the committee on various issues relating to sensitive technologies such as telecommunications, electronics, etc. that fall within the jurisdiction of the EAR. Brent holds a BS in Electrical Engineering from Letourneau University, Longview, Texas.