Earl Comstock

Senior Policy Counsel, Washington, DC



Earl is a Senior Policy Counsel in the International Trade group, and an active member of our economic sanctions and export controls practice. He has extensive experience shaping government policy in the Executive Branch and Congress. Earl assists clients in finding the right approach to government to resolve complex problems. He has legal and policy expertise in diverse areas, including international trade, national security, export controls, emerging technologies, advanced manufacturing, telecommunications, commercial operations in space, and fisheries.

Earl was the director of policy and a senior advisor to the US Secretary of Commerce, Wilbur Ross, from 2017 to 2020. In this capacity, he was instrumental in the development and implementation of Section 232 tariffs and the expanded foreign direct product rule that is applied to the Entity List. He also worked for the US Senate for over a decade, serving as legislative director for a senior member of the Senate Committee on Appropriations and as staff on the Senate Committee on Commerce, Science, and Transportation. Earl played a pivotal role in the negotiation and drafting of the Telecommunications Act of 1996 and a dozen other major bills that became law. He has successfully resolved legal and policy issues in both domestic and international settings working with Federal agencies, the US Congress, non-governmental organizations, trade groups and the private sector.

Bars and Courts
District of Columbia
US Supreme Court
US Court of Appeals for the District of Columbia Circuit
US Court of Appeals for the Ninth Circuit
US District Court for the District of Alaska
George Mason University School of Law (Antonin Scalia Law School)
Political Science
University of California

Santa Barbara



Speaking Engagements

"Free Trade Agreements: What they mean for Kenya and Africa", November 24, 2020, Webinar presented by Anjarwalla & Khanna in collaboration with the American Chamber of Commerce (Kenya)