Export Controls have long been a critical regulatory hurdle impacting space and satellite companies. Over the last couple of years, the U.S., EU and UK have rapidly expanded trade regulations well beyond export controls to include a broad and complex web of national security-related controls on exports, imports & supply chains, and cross-border investments. Given the space industry’s reliance on advanced technologies with significant military applications, every company in the space industry is impacted by these restrictions. The companies that invest in navigating these restrictions early on in their life cycles will substantially reduce their compliance risks and will have a critical advantage over their competitors. The panel will discuss recent developments and what’s coming in international trade regulations and provide recommendations for navigating the challenges associated with these restrictions.
Export Controls: Despite the U.S. Government’s Export Control Reform initiative ten years ago, commercial spacecraft and related items remain highly controlled under U.S. export control regulations. The control lists are badly in need of updates to account for technological advancements in the commercial space industry over the last 10 years. In October 2024, the Biden Administration announced a complex set of interim and proposed updates to the U.S. export controls for spacecraft, launch vehicles and related technologies. Meanwhile, in Europe and in the UK, the legislators are increasingly expanding the scope of their national security laws to capture a broad range of “sensitive” items and activities and protect critical space industry technologies. In addition, collaboration between the U.S. and European and UK partners is increasing, with government-to-government agreements for commercial launch collaborations and implementation of the AUKUS security cooperation agreement between the U.S., the UK and Australia. – Import Restrictions and Supply Chain Security: During his first administration, President Trump issued an Executive Order authorizing the Commerce Department to impose restrictions on imports into the United States to protect America’s infrastructure and supply chains for Information and Communications Technology and Services (ICTS). In late 2024, the Commerce Department announced complex and burdensome new restrictions on imports of hardware and software for “connected vehicles” from “foreign adversaries” such as China. The Commerce Department plans to issue similar rules for drones and satellites. Once imposed, these restrictions will force space industry companies to maintain full visibility into their supply chains and certify to the U.S. Government that their system do not incorporate components from China or other foreign adversaries. – Cross-Border Investment Restrictions: The U.S. Government also added important new restrictions on cross-border investments but expanding its long-standing “CFIUS” process for review foreign investment into the United States and adding a brand-new review process for “outbound” investment. These cross-border investment controls limit the ability of space industry companies to take advantage of foreign capital, as well as international labor and technology sources. The Hogan Lovells International Trade & Investment team was recently ranked Band 1 Elite by Chambers USA. The panel would be led by Stephen Propst, our partner in Washington, D.C., who has 25 years of experience advising space and satellite industry clients on all aspects of Export Controls. He would be joined by Hogan Lovells Partners Aline Doussin from our London and Paris Offices who also has extensive experience advising space industry clients. We would also invite one or two clients to join.
Stephen Propst
Stephen Propst helps clients in navigating complex issues under U.S. export controls, economic sanctions and related national security regulations. He brings industry sector knowledge and a commitment to practical, business-focused solutions to his relationships with aerospace & defense, space and satellite, telecommunications, automotive, advanced computing and higher education clients.
Stephen has a wealth of experience advising clients regarding a full range of regulatory and enforcement matters under the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). He is also advising automotive and drone industry clients extensively on the rapidly expanding Commerce Department regulations applicable to Information and Communications Technology and Services (ICTS). Since 2017, he has led Hogan Lovells’ representation of ZTE Corporation in the implementation in its landmark settlement agreements with the U.S. Government, among the largest export enforcement cases and corporate monitorships in U.S. history.
Stephen has particular strength and experience in advising telecommunications and space industry clients, including manufacturers and operators of communications satellites, remote sensing satellites, space-based logistics vehicles, ground system manufacturers, as well as launch services providers and communications equipment suppliers.
In 2014, Stephen wrote a groundbreaking legal analysis that was presented at the Brookings Institution and served as the roadmap for President Obama’s historic changes to the U.S. embargo against Cuba.
Stephen previously served as the Co-Chair of Hogan Lovells’ global matched charitable giving campaign. He also served as member of the Board of Directors of Gifts for the Homeless, a non-profit charitable organization that donates money and clothing to benefit the homeless in the Washington, D.C. area.
Practices: International Trade and Investment; Space and Satellite; Sovereigns
Education: J.D., University of Virginia School of Law, 1998; M.P.P., Duke University, 1998; B.A., Princeton University, 1992
Recognitions: Recognized by Chambers Global for Export Controls and Sanctions (2020-2025); Recognized by Chambers USA for Export Controls and Sanctions (2019-2023)
Aline Doussin
Ranked as a Band 2 attorney by Chambers UK for her sanctions experience, and as a Leading Partner by Legal 500 UK for her international trade work, Aline Doussin leads the International Trade and Investment team in London. As a triple-qualified lawyer (Avocat au Barreau de Paris and Solicitor in England and Wales, and registered with the Milan bar), she represents companies on the full range of international trade law and policy issues, including export controls, sanctions, anti-money laundering, customs, and trade remedies.. Additionally, Aline advises companies with respect to Foreign Direct Investment screening in France and the UK, as well as advises on national security laws in those jurisdictions. She provides clients with the full spectrum of support ranging from advisory, advocacy, audits, investigations, and litigation.
Aline has particular expertise in the space and satellite sector, and supports companies operating in this heavily regulated industry on all aspects of their international trade operations. Her support ranges from export controls, customs, and sanctions compliance. Aline has specific experience representing compliance in obtaining Foreign Direct Investment screening clearances for space and satellite companies.
Representative Experience:
• Advising SES on the USD 3.1b purchase of Intelsat.
• Advising on FDI for Gogo Inc’s $375million acquisition of Satcom Direct.
• Advised ALL.SPACE Networks, a satellite communications company, on a series of pre-revenue equity fundraisings.
In 2019, she was appointed by the UK Government to the Department of International Trade (“DIT”) – Expert Trade Advisory Group.