Sarah Oliai

I help companies navigate complex export controls, CFIUS, and economic sanctions regulations, with deep experience across cutting-edge technology sectors.

Sarah Oliai’s practice focuses on helping companies navigate complex regulatory issues at the intersection of international trade and national security. She advises clients on CFIUS, export controls (ITAR and EAR), and OFAC economic sanctions.

Sarah has deep experience across a range of cutting-edge technology sectors, advising clients at all stages of maturity, from founding through post-public offering, on national security regulations that are critical to the growth of their businesses. Her practice focuses on Committee on Foreign Investment in the United States (CFIUS) regulations, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).

Sarah provides strategic guidance across all aspects of transactions, compliance, and enforcement matters. Her transactional work includes regulatory due diligence, analyses, as well as CFIUS filings and negotiating national security agreements. She also provides counsel on a range of regulatory compliance matters, including the development of compliance policies and procedures, technology control plans, and training programs. She advises on export commodity jurisdiction, classification, and licensing, voluntary self-disclosures, and ITAR registration matters, as well as conducts EAR de minimis and foreign direct product rule analyses. She also provides guidance on compliance with OFAC sanctions programs, licensing, and voluntary self-disclosures.

Sarah also maintains an active pro bono practice, with a focus on immigration/refugee issues, election protection and voting rights, and wrongful conviction matters, and she volunteers regularly with several organizations in the Washington, D.C. metropolitan area.

Previously, Sarah served as a law clerk for a federal judge on the U.S. Court of International Trade, researching and drafting opinions in customs classification and anti-dumping duty cases, and served as a fellow at the Legal Aid Society of the District of Columbia, assisting clients with federal and District of Columbia public benefits matters. She also consulted for the World Bank Group, analyzing draft legislation in Spanish on topics including customs enforcement, weapons control, money laundering and human rights. She is fluent in Spanish and has intermediate proficiency in Persian/Farsi.

Sarah has been nationally ranked by Chambers USA as a CFIUS "Associate to Watch" (2021–2026) and is recognized in The Legal 500 US for Customs, Export Controls and Economic Sanctions (2025).

Related Industries

Related Practices

Education

University of Michigan Law School, J.D., 2014
Michigan State University, James Madison College of Public Policy, B.A., International Relations, with honors, 2010

Bar and Court Admissions

Bar Admissions:

District of Columbia
New York

Court Admissions:

U.S. Court of International Trade

Languages

Spanish (Professional Proficiency)
Persian / Farsi (Intermediate Proficiency)

Experience

CFIUS Experience

Guided a quantum company through multiple CFIUS filings, conducted critical technology analyses, and advised the company on export control compliance and licensing requirements for its novel quantum computing technologies.
Guided a leading provider of application development, integration, and identity / access management software through a CFIUS filing related to its acquisition by a leading foreign private equity firm and advised the company on export control and sanctions compliance matters, including classification of its software products.
Guided a space technologies company through multiple CFIUS filings, concurrently advising the company on ITAR and EAR compliance matters, and advised the company across various financings and strategic partnerships on CFIUS and export control compliance matters.
Advised a biotechnology company on CFIUS and export control compliance matters across several financings, including guiding the company through multiple CFIUS filings, negotiating national security agreements, classifying the company’s hardware and software for export control purposes, and advised the company on the development and implementation of an export control compliance program for its cutting-edge technology.
Represented the venture fund of a publicly traded foreign Fortune 500 technology conglomerate on CFIUS matters, obtained CFIUS clearance for the fund’s investments in U.S. technology companies, and provided strategic and transactional guidance for the fund’s portfolio investments across technology sectors including industrial, manufacturing, and agriculture automation technologies; robotics; enterprise software solutions; battery and energy management technologies; IoT; and operations management software solutions.
Advised a foreign automotive developer in obtaining CFIUS clearance for its acquisition of a U.S. automotive developer, including negotiating a supply assurance national security agreement.
Advised multiple companies across industries—including semiconductor technology, software, and life sciences / biotechnology companies—in responding to CFIUS non-notified inquiries.
Regularly conduct CFIUS critical technology, critical infrastructure, and sensitive personal data analyses for companies across industries.

Export Controls Experience (ITAR & EAR)

Advised a publicly traded semiconductor company on export control compliance, including successfully obtaining and negotiating the scope and terms of BIS licenses, advising on export control classification and licensing requirements for multiple generations of product families, and providing export compliance training to key personnel. Advised the company on responding to CFIUS non-notified inquiries and compliance with the OISP.
Advised a developer of space-qualified solar cells on the export control classification of its products, obtained a deemed export license for a key employee, and advised the company on CFIUS and export control matters across multiple financings and its acquisition.
Advised a developer of mobile, connected toolsets on export control compliance matters, including preparing and obtaining on an expedited basis a license for the export of controlled sensors for the development of prototype mobile, connected toolsets for frontline defense and industrial workers.
Advised a space technology and life sciences company on ITAR and EAR compliance, including export control classifications of its technologies, licensing requirements, and developing strategies to minimize regulatory licensing obligations to facilitate partnerships with and operations in allied countries.
Advised contract manufacturers and custom product developers on ITAR and EAR compliance and licensing requirements.
Conducted de minimis and foreign direct product rule analyses for semiconductor and software developers and provided guidance on compliance with the EAR.
Advised an early-stage developer of command-and-control technology products on ITAR and EAR jurisdiction, licensing (deemed export, physical exports, and technical assistance agreements), and compliance in their efforts to support Ukrainian defense efforts and counter-unmanned aerial systems support in conflict zones.
Advised an enterprise resource planning software developer on ITAR and EAR compliance, including advising on the development of product offerings designed to support compliance with export control requirements.
Advised defense technology companies developing modular unmanned systems in structuring core product lines to maximize the ability to sell commercially and manage ITAR and EAR compliance requirements.
Advised clients across industries—including quantum, space, defense, and satellite technologies and contract manufacturers—on ITAR compliance matters, including licensing; technical assistance agreements; jurisdiction analyses and classification; mergers, acquisitions, and divestitures (MAD) notifications; and registration requirements.
Developed tailored EAR and ITAR compliance policies, procedures, and technology control plans for multiple companies across various industries, including developing hiring policies to balance anti-discrimination employment law requirements and export control licensing requirements specific to the client’s technology.
Provided export compliance trainings for companies across industries on EAR, ITAR, OFAC, and anti-boycott compliance, and provided export compliance, empowered official, and broker training for key personnel of various defense technology companies.

Sanctions Experience

Prepared and advisory opinion for an internet registry service provider and license applications for software developers and provided guidance regarding sanctions jurisdiction.
Advised software development companies on sanctions compliance related to engaging independent software developers in Venezuela.
Analyzed OFAC sanctions compliance requirements for a blockchain analytics company and provided guidance on compliance with OFAC sanctions in support of a governmental investigation.
Advised life sciences companies on compliance with general licenses and OFAC licensing requirements for IP filings in sanctioned countries.
Provided sanctions compliance guidance to software developers that suspected remote workers of being associated with the North Korean government.
Provided guidance to clients in response to compliance inquiries from financial institutions related to payments of foreign patent agents and advocated for clients before financial institutions on compliance diligence related to such payments.

Investigations and Voluntary Self-Disclosures

Advised a social medial platform on EAR and OFAC compliance and its internal investigation of potential EAR and OFAC violations relating to users making subscription payments with payment methods designed to evade sanctions and export control restrictions, resolving without penalties voluntary self-disclosures submitted to BIS and OFAC.
Advised a quantum computing company on EAR and OFAC compliance and steps to conduct an internal investigation relating to potential violations as part of due diligence efforts related to a strategic transaction.
Advised a multinational industrial explosives and agricultural fertilizer company on its internal investigation and remediation efforts and prepared a voluntary self-disclosure to OFAC of an attempted diversion of the fertilizer compound to an embargoed country, resulting in no penalties.
Advised and prepared voluntary self-disclosures on ITAR compliance matters for defense technology companies, including a military training software company and a space technologies company.

Related Professional Experience

U.S. Court of International Trade, Clerkship (2015 – 2016)
Deloitte Tax, LLP, Global Trade Advisory, Senior Consultant (2017 – 2019)

Publications

Blog Post 08/25/2026

Trump Administration Increases Sanctions Pressure on Iran through “Operation Economic Outcast”

Blog Post 07/21/2026

DOJ Announces First FCPA Deferred Prosecution of 2026: Key Takeaways from Scoular’s $10 Million Resolution

Honors

Honors

Chambers USA: International Trade: CFIUS Experts – Nationwide (Associates to Watch; 2021–2026)
The Legal 500 US: Customs, Export Controls and Economic Sanctions (2025).