Professional profile
About Kathrine
US Export Controls, OFAC Sanctions and Compliance Counselling in Houston
Kathrine Boer advises multinational companies, financial institutions and Chinese outbound investors on US export controls, economic sanctions and trade compliance programmes, with a practice focused on practical licence analysis, transaction screening and export compliance programme (ECP) development in Houston.
Kathrine Boer practises at Boer & Hendricks, LLP in Houston. She concentrates on US international trade controls, including the Export Administration Regulations (EAR) administered by BIS, the International Traffic in Arms Regulations (ITAR) administered by the Department of State, and the sanctions and embargo programmes administered by OFAC. Her clients operate in sectors where export-control and sanctions risk has become a daily operational issue: semiconductors and advanced computing, telecommunications equipment, high-end manufacturing, energy and financial services.
Her approach is commercial and preventive: translate complex regulatory requirements into decisions that business teams can actually apply, identify compliance risk before it becomes an enforcement matter, and keep the programme aligned with how the company really ships, pays and hires.
Ongoing sanctions and export-control counselling
US controls change frequently, and the list of affected countries, sectors and items can shift with each new rule, designation or licence policy. Kathrine Boer provides ongoing legal support that keeps pace with those changes.
- Policy assessment and compliance guidance: monitoring EAR, ITAR and OFAC developments affecting specific countries, regions and industries, including semiconductors, artificial intelligence and quantum computing, and preparing written compliance assessments.
- Re-export and multi-country rules: analysis of restrictions on the re-export or transfer of US-origin goods, software and technology from third countries, and application of the Foreign Direct Product Rule (FDPR) to products containing US-controlled content.
- Embargo and country-specific programmes: practical guidance on dealing with sanctioned regions and parties while preserving lawful trade and payment routes.
The objective is a compliance position the client can defend, with the source rules, dates and reasoning documented for later audit.
Controlled-item classification and licensing
Every export or re-export starts with the right classification. Kathrine Boer helps clients map products and technology to the correct control category so that licensing, exceptions and record-keeping follow the right path.
- Classification and ECCN determination: preparation of official Commodity Classification Automated Tracking System (CCATS) requests to BIS where a formal determination is appropriate, and documented self-classification for routine items on the Commerce Control List (CCL).
- Licence applications: preparation and filing of BIS and OFAC licence applications where a transaction requires authorisation, including end-user and end-use statements, and establishment of post-approval tracking and audit records.
- Deemed exports and foreign nationals: analysis of deemed-export rules where foreign-national employees or visitors may access controlled technology, and coordination with immigration counsel on H-1B, L-1 and other visa processes.
Classification work is most useful when it is embedded in engineering and supply-chain decisions, before contracts are signed and before goods move.
Compliance programme design and transaction screening
A defensible compliance posture depends on a programme that is actually used. Kathrine Boer helps companies build and assess export compliance programmes (ECPs) that match their risk profile and transaction flow.
- ECP development and assessment: review and construction of written procedures, screening questionnaires, management manuals and sanctions clauses in contracts, aligned with BIS Export Compliance Programs guidance and OFAC's Framework for Compliance Commitments.
- Automated screening: guidance on deploying and optimising sanctions-list and denied-party screening so that customers, suppliers and intermediaries are covered consistently, including evaluation of screening tool configuration and false-positive handling.
- Training and testing: practical training materials and scenario-based testing so that export-control and sanctions responsibilities are understood by the people who quote, ship, pay and hire.
Programme work is calibrated to the company's actual exposure: a trading company with a narrow product line does not need the same architecture as a technology manufacturer with global facilities.
How to engage and what to prepare
Engagements are confirmed in writing, including scope, fees and communication protocols. Kathrine Boer does not promise outcomes; the commitment is accurate analysis, disciplined preparation and clear updates as facts evolve.
When using this profile's contact form, please include: the parties and jurisdictions involved; the products, technology or software at issue and any existing classifications; the countries of origin, destination and routing; whether the matter involves new business, a licence application, an audit or an investigation; and the first document set you can share.
If in-house compliance staff, logistics providers or immigration counsel are already involved, say so at intake. Coordinated messaging reduces inconsistent statements across channels and keeps the compliance programme aligned with commercial reality.
Houston practice and cross-border perspective
Houston is one of the busiest US gateways for energy, petrochemicals, equipment and technology moving to and from overseas markets, and its port, logistics and banking infrastructure make it a natural base for companies managing US-China trade flows. Kathrine Boer's Houston practice reflects that operating reality: she routinely works with exporters, distributors, banks and logistics providers whose day-to-day questions involve classification changes, new sanctions designations, and contract terms that need to reflect current controls.
For Chinese outbound companies, the US side of a transaction is rarely the only legal layer. Kathrine Boer coordinates with Chinese counsel on the interaction between US controls and Chinese export-control, countermeasure and data requirements, so that a compliance decision made for the US leg does not create an unintended conflict on the China side. She also works with UK, EU and other international counsel where a transaction touches multiple control regimes, keeping the analysis jurisdiction-specific rather than assuming one set of rules applies everywhere.
Her engagement model is designed for companies that need answers quickly and consistently: written positions, clear assumptions, and practical next steps that can be implemented without re-opening the same question at every approval gate.
Capability
