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Countering America’s Adversaries Through Sanctions Act of 2017- Additional Parties and Sanctions Added

On September 29, 2017, the President delegated the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), which became effective July 28, 2017, to the authority of the Secretary of State.  Additional parties and sanctions were just added on September 20, 2018. Under the provisions of this Act sanctions were imposed on certain persons (individuals and entities) […]

Automated Export System Shipment Reminders

If your company exports goods valued at more than $2,500 per Schedule B number to anywhere other than Canada or goods that require an export license, the regulations require that you submit the Electronic Export Information (EEI) through AES (Automated Export System). AES filing is exempt for shipments of BIS controlled .y. paragraph 9×515 or “600-series” items with a value of $2,500 […]

Company Security Requirements- U.S. Government Including DOD Controlled Information

Information that has been provided to a company directly by a U.S. Government (USG) agency, including DOD, or through another company must be controlled in accordance to USG stipulated controls and safeguards to protect this information from unauthorized access. The National Industrial Security Program Operations Manual (NISPOM) provides specific requirements, restrictions, and other safeguards to […]

New Russia Sanctions to be Imposed in August 2018 by the U.S. Department of State

Chemical and Biological Weapons (CBW) Sanctions which will be imposed on Russia by the U.S. State Department on or about August 22, 2018 include the imposition of a “presumption of denial” for export licenses for US origin national security-sensitive goods and technology controlled by the US Department of Commerce’s Export Administration Regulations to any Russian […]

Avoid Doing Restricted Business with North Korea or Other Sanctioned Countries

The U.S. State Department has issued an alert to companies who may be doing business with North Korea and are unaware of the fact that North Korea is masking and misrepresenting services and goods produced in North Korea and exported under a different name, or providing service and manufacturing products by a company outside of […]

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 […]