Richard D. Key

Richard Key advises companies operating across borders on a wide range of export controls, economic sanctions, customs, government contracting, and international trade matters, with a particular focus on the regulatory risks facing the aerospace, defense, manufacturing, and government contracting sectors. Clients rely on him to help navigate the legal and business issues that arise when working with federal agencies, defense programs, and international partners.

Richard has managed high-value government contract portfolios, negotiated significant awards, and advised stakeholders on matters involving the Federal Acquisition Regulation (FAR), the Defense Federal Acquisition Regulation Supplement (DFARS), the Homeland Security Acquisition Regulation (HSAR), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR).

Before joining Miller Canfield, Richard served in a series of contract management, compliance, quality, and government property leadership roles at a leading global aerospace and defense manufacturing company, where he oversaw complex defense programs and supported business operations involving U.S. military and foreign military customers, giving him a practical understanding of the operational challenges his clients face.

Export Controls & Economic Sanctions

Richard advises clients across a range of industries on compliance with the Export Administration Regulations (EAR), administered by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS); the International Traffic in Arms Regulations (ITAR), administered by the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC); and U.S. economic sanctions laws and regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). His experience includes export jurisdiction and classification analyses, restricted-party and prohibited-transaction reviews, and transaction due diligence. Richard also assists clients in developing and implementing risk-based export and import compliance programs, including classification frameworks, technical control plans, written procedures, screening and due-diligence protocols, recordkeeping processes, and internal compliance tools. He helps clients translate regulatory requirements into practical controls that can be integrated across legal, engineering, procurement, supply chain, contracts, and business functions.

Customs and Import Compliance

Richard advises clients on interpreting and complying with U.S. Customs and Border Protection (CBP) requirements. His experience includes classifying merchandise under the Harmonized Tariff Schedule of the United States, conducting country-of-origin analyses, assessing eligibility for preferential tariff treatment, and developing practical processes to support accurate import declarations and recordkeeping.

Government Contracting & Supply-Chain Compliance

Richard counsels prime contractors and subcontractors on interpreting and complying with the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS), including provisions that must be flowed down to subcontractors. He also advises clients on domestic-content and sourcing requirements under the Buy American Act, the Berry Amendment, specialty-metals restrictions, and restrictions on the acquisition of certain magnets. Richard further advises clients on supply-chain due diligence and compliance considerations involving entities identified by the Department of War (DoW) as “Chinese military companies” under Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021.