Lieutenant Colonel David Greenless, USMC (Ret.)

ITAR/EAR export controls and defense trade compliance advisor

David Greenlees helps companies, investors, and research institutions identify and manage U.S. export-control risk under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). He advises organizations entering defense and dual-use markets, evaluates existing compliance programs, conducts export-control due diligence for acquisitions and investments, and helps clients resolve potential compliance issues before they become enforcement problems.
His work includes jurisdiction and classification assessments, DDTC registration and licensing, defense services and technical-data issues, foreign-person access, brokering, voluntary disclosures, compliance program development, transaction due diligence, and remediation of identified deficiencies. For organizations seeking an initial assessment, David also conducts focused export-control “health checks” designed to identify significant areas of risk and provide a practical roadmap for addressing them.

David developed his regulatory expertise during eight years with the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC), where he evaluated hundreds of voluntary and directed disclosures, participated in major ITAR enforcement matters, and managed State Department consent agreements and compliance monitoring. Since leaving DDTC, he has advised U.S. and international companies on ITAR and EAR compliance, served as a Special Compliance Official under a State Department consent agreement that concluded more than a year ahead of schedule, and advised on export-control and CFIUS issues arising from corporate transactions.

He is an appointed member of the State Department’s Defense Trade Advisory Group and regularly teaches ITAR and EAR compliance to industry.

A retired U.S. Marine Corps lieutenant colonel, David served for 24 years as a field artillery officer and in other operational and staff assignments, including combat service in Iraq and as Operations Officer in the Marine Corps Office of Legislative Affairs.

David holds a J.D. from Thomas Jefferson School of Law and a B.A. in criminal justice from George Washington University. He is licensed to practice law in California, Michigan, and the District of Columbia.

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