Sara Crossman has extensive experience advising clients on the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), Department of Energy (DOE) Part 810, Nuclear Regulatory Commission (NRC) Part 110, and the Foreign Trade Regulations (FTR).

Below is a brief timeline of her experience with significant export controls compliance matters:

• 2024-2025: Sara was the overall lead auditor for a major U.S. aerospace and defense company’s first Consent Agreement-directed audit. As part of this effort, she wrote the Audit Plan, created the audit methodology, drafted all questions lists, developed transaction testing, provided training to all members of the audit team, led site visits, reviewed all reports, performed quality control on all transaction testing, and ensured consistent, high-quality work for the client. 

• 2024-2025: She worked with one of the largest aerospace and defense companies in the world to assess their U.S. jurisdiction and classification program.

• 2024-2025: She supported a large, multinational semiconductor company and their outside counsel with a series of investigations and responses to U.S. government requests for information.

• 2023-2024: Sara was the overall lead auditor for a U.S. aerospace and defense company’s second Consent Agreement-directed audit. As part of this effort, she wrote the Audit Plan, created the audit methodology, drafted all questions lists, developed transaction testing, provided training to all members of the audit team, led site visits, reviewed all reports, performed quality control on all transaction testing, and ensured consistent, high-quality work for the client.

• 2022-2023: She was the transaction testing lead auditor for a major non-U.S. aerospace and defense company’s second Consent Agreement-directed audit during Fall, 2022. Sara provided eight hours of training to the entire 40-person audit team to drive consistency and highlight key areas to focus on for a second audit; she led overall transaction testing and report writing for the transaction testing that was performed at 24 sites globally, and she personally led transaction testing at seven sites in five countries.

• 2022-2025: She was selected to serve as the Special Compliance Officer (SCO). As part of her role as SCO, Sara oversaw enhancements to the company’s policies, procedures, and training during Summer and Fall, 2022, as well as the company’s two Consent Agreement-directed audits.

• 2019-2021: Sara led an internal investigation for a multinational technology company that manufactures ITAR- and EAR-controlled parts and components in the U.S. and abroad, and exports, reexports, and retransfers the parts and their associated technical data and technology. She also worked with FTI’s Data & Analytics practice to piece together the history for over 2.3M technical data and technology accesses from disparate IT systems and incomplete records to develop an understanding of the company’s compliance with the ITAR and the EAR.

• 2019: She led a major logistics provider’s BIS Settlement Agreement-directed second audit; she performed audit planning activities, led interviews, and was the principal author of the final report.

• 2018-2019: She worked on a U.S. company’s Consent Agreement-directed first audit as the account manager until she joined FTI in September, 2019. As part of that project, she developed the Audit Plan as well as the work papers and templates used for the audit.

• 2018: She led a major logistics provider’s BIS Settlement Agreement-directed first audit; she performed audit planning activities, led interviews, and was the principal author of the final report.

• 2016-2019: She provided support to a non-U.S. company under a multi-jurisdictional Settlement Agreement with the U.S. government, over the course of approximately three years. This experience ranged from acting as the project manager, drafting compliance policies and procedures, researching and documenting corporate structure for submission to the monitor and U.S. government, and performing audit preparation with dozens of individuals at the company prior to monitor or external audits.

• 2015-2016: She co-project managed a major U.S. aerospace and defense company’s second Consent Agreement-directed audit. In that role, she developed the Audit Plan, created the overall work papers and templates for the audit, and drafted and finalized the audit report. She worked closely with the export compliance leads at the company and with the SCO on a daily basis to keep the audit running smoothly. In addition, she was responsible for all testing at the 30 sites in scope for the audit, training all transaction testing team members, and she personally performed the audit and transaction testing at the company’s corporate research and development (R&D) site due to the unique export compliance issues that arise with R&D.

• 2014-2015: She was the transaction testing lead for an aerospace and defense company’s first Consent Agreement-directed audit. In this role, she developed all testing templates, trained the transaction testing team, managed testing requests to the client, provided quality assurance on all testing performed, and briefed the client and the SCO weekly on progress and observations.

In addition to the significant export controls compliance matters described above, Sara has assisted dozens of other clients with smaller projects between 2014 and 2025. Prior to starting her career as a consultant, Sara worked at MIT Lincoln Laboratory between 2010 and 2014 as an export controls professional who:

• Drafted applications for licenses, agreements, and general correspondence from the Directorate of Defense Trade Controls (DDTC).

• Reviewed and approved foreign shipments, foreign visitor requests, international travel requests, hand carry requests, and university research subcontracts.

• Drafted high-risk travel memos for submission to senior management explaining the risks posed by the proposed activity in the high-risk territory (determined by either the Department of State, Department of Defense, or MIT).

• Performed export compliance review of documents submitted for public release.

• Conducted a weekly presentation to all new employees on export controls. 

• Developed and launched PARROT, the Lab’s automated system for reviewing and releasing information, created user documentation, and provided laboratory-wide training.

• Maintained and updated policies, procedures, forms, and content for the export controls and release review intranet websites.

• Trained and assisted staff in using export compliance processes, policies, and systems.