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Foreign National Employee License Requirements

If you have foreign national employees, it may be necessary to secure BIS or DDTC licensing for those employee to access controlled technical data and/or product.  Foreign national employees are employees who are neither U.S. citizens, lawful permanent residents (i.e. Green Card holder), nor an individual who is granted status as a “protected person” under 8 U.S.C. 1324b(a)(3). […]

Export Licensing Requirements for Foreign Trade Shows

If your company will be participating and exhibiting products at Air Shows or Trade Shows, it is important that any military/defense products, including parts/components, are not forwarded/exported or taken with company employees to the trade show without required State Department or Commerce Department licensing authority or use of a license exemption/exception. There is also a […]

The Import Side of Export Compliance

Important issues to address when exporting product from the U.S. include ensuring that appropriate export licensing authority, including a license or applicable exception/exemption is provided for that export sale; and that shipment certifications are obtained. There are, however, other important considerations and provisioning that should be addressed and provided for with regards to the return […]

International Air Shows- Export Compliance Considerations

Your yearly reminder regarding Air Shows: If your company will be participating and exhibiting products at Air Shows (Berlin Air Show, Eurasia Air Show, Farnborough Air Show, etc.) it is important that any military/defense, including parts/components, or other ITAR/EAR controlled products, are not forwarded/exported or taken with company employees to the air show without required […]

Minor Amendments to DDTC Agreements

Some changes to agreements (TAAs, MLAs, and WDAs) do not require approval by DDTC before going into effect. Changes that can be made via minor amendment are limited to revisions that do not change the scope of the agreement. DDTC has an inclusive list of what changes are allowable by minor amendment; these include (but […]

South Sudan Sanctions-Update

On February 14, 2018 the Department of State (DDTC) amended the International Traffic in Arms Regulations (ITAR) to prohibit exports, imports, and sales to and from South Sudan.  DDTC has implemented a policy of denial on the export of defense articles and defense services, with certain specific exceptions which include exports for United Nations operations […]

Destination Control Statement

As a reminder, the stipulated Destination Control Statement is required to be printed on all commercial invoices for shipments of all ITAR and most EAR jurisdiction items. Items classified as EAR99 or exported under license exception BAG or GFT will continue to not require a Destination Control Statement.  The Destination Control Statement for both State/Commerce […]

South Sudan Sanctions

On February 2, 2018, the State Department announced they will be executing limitations on the export of defense articles and services to South Sudan. This announcement is in response to the worsening humanitarian crises in South Sudan, with killings of aid workers on the rise, in addition to a worsening famine and refugee crises.  The State Department […]

Annual Reports of Sale

Annual Reports of Sale are required to be submitted to DDTC for Warehouse and Distribution Agreements and Manufacturing License Agreements. These report should only include what was manufactured (MLA) or distributed (WDA) from the foreign party, not what was exported to the foreign party from the U.S. party. Only actual transfers of hardware by the […]

JCPOA Statement Issued

On January 12, 2018, the Trump Administration released a statement regarding JCPOA, the international agreement regarding limiting Iran’s nuclear capabilities. While not pulling the US out of the agreement at this time, it outlined required changes that must be made in a supplemental agreement for the US to remain a party to JCPOA. This includes […]