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Clifford Chance

Clifford Chance
Josh Fitzhugh

Josh Fitzhugh


Josh Fitzhugh

Joshua Fitzhugh’s practice focuses on export control and international sanctions law, anticorruption compliance, international trade regulation, customs law issues, global trade agreements and national security law.

Josh is a highly experienced trade control, anti-corruption and international trade lawyer with nearly two decades of experience in private practice, in-house executive and government positions.

Prior to joining Clifford Chance, he served as Vice President and Group Head of Trade Controls for one of the world’s largest defense contractors – BAE Systems plc in London. In that role, he was responsible for managing global trade controls, including export controls, sanctions and trade compliance for all BAE Systems divisions not subject to a U.S. special security agreement.

Josh led BAE’s response to a 2011 consent agreement with the U.S. Department of State, including managing the group’s legal obligations and improvement program; directing export control and sanctions investigations, compliance and licensing; enhancing export control and related policies, procedures and processes; managing the group’s exposure to trade control risk; establishing and leading the trade control function; and managing compliance relationships with government regulators, industry and other external and internal stakeholders.

For more than three years, Josh acted as Internal Special Compliance Official for the BAE Systems plc-managed entities, monitoring and reporting to the State Department on the group's progress under the consent agreement. In this capacity he engaged with most key US trade control officials in both the Obama and Trump Administrations, as well as many of their permanent staff.

Prior to his six year at BAE Systems, Josh worked for nearly a decade at Pillsbury Winthrop Shaw Pittman, where he was a Counsel in that firm’s International Trade Group. While there, his practice concentrated on export control, national security, sanctions, international anti-corruption and trade laws.

Josh previously worked in the U.S. Department of Commerce's International Trade Administration and the U.S. Department of State's Office of the Legal Adviser.

Josh has represented a range of US and non-US clients in compliance and enforcement matters before the US Department of State, US Department of Commerce and US Department of Treasury, and in litigation at the federal district, appellate and US Supreme Court levels.

  • Advice on the development, review and enhancement of risk-based trade compliance programs that work in both US and non-US environments and integrate export controls, sanctions, anti-corruption, national security and related fields
  • Performance of US and multijurisdictional compliance investigations and disclosures, provision of investigatory support and counseling and enforcement action support
  • Sanctions compliance counseling and support
  • Advice on compliance with changing regulatory frameworks such as US Export Control Reform
  • Consent agreement/deferred prosecution agreement counsel and support
  • Acting as a special compliance official for companies under consent and deferred prosecution agreements
  • Assurance and external audit support
  • Regulator relations and external stakeholder engagement
  • Support and advocacy on regulatory, legislative and policy matters
  • Jurisdiction and classification support, including interpretation and application of control lists, commodity jurisdiction applications and appeals and strategic planning to proactively manage jurisdictional and classification risk
  • Multijurisdictional compliance strategy and risk management counseling

Contact details

Career and qualifications

  • Colby College B.A. (Political Science and Government, Anthropology) 1992
  • Georgetown University Law Center (J.D.) 1998
  • Admitted as an Attorney-at-Law in California 1998
  • Admitted as an Attorney-at-Law in the District of Columbia 1999
  • Joined Clifford Chance 2017