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Revocation of Certain Sanction Regarding Sudan

Effective October 12, 2017, the Office of Foreign Assets Control is revoking many of the sanctions on Sudan.  Sudan, however, continues be included on OFAC’s and BIS’s lists as a State Sponsor of Terrorism (SST) and applicable restrictions pertain. With the revocation of existing OFAC sanctions exports to Sudan are permissible for export by use […]

The Entity List

A key component to a company’s export compliance program should be screening of the U.S. government export sanctioned lists prior to shipment. Lists that should be screened include: Denied Persons List (EAR), Entity List (EAR), Unverified List (EAR), Debarment List (ITAR), Sanctioned Parties List (ITAR), Nonproliferation Sanctions List (ITAR), and Specially Designated Nationals (OFAC).   […]

Year End Review of Export Compliance Requirements

Another year is coming to a close in a few months making this a good time to review your export compliance program and determine any deficiencies to be addressed prior to year end.   Training: All employees who are involved in export- decision making should receive training on a yearly basis.  Additionally, any new export […]

Schedule B (Statistical Classification of Commodities Exported from the United States) Requirements

A Schedule B number is a 10-digit number used to classify specific commodities on their export from the U.S.  This numeric number qualification of articles is required for the U.S. Government – Census Bureau to gather and report statistics on specific goods exported including: quantity/value, destination country and if the goods are U.S. or foreign origin.    Schedule […]

Who is a U.S. Person?

A U.S. person, in terms of export licensing, is any U.S. citizen, lawful permanent resident (i.e. Green Card holder), or individual who is granted status as a “protected person” under 8 U.S.C. 1324 b(a)(3). It also includes dual-citizens of the U.S. and another country. Foreign Nationals are non-U.S. persons (including those with work authorizations). Additionally, […]

Pratt Canada Debarment Rescinded

As of July 12, 2017, Pratt & Whitney Canada’s 2012 statutory debarment  was rescinded. Statutory debarments may be rescinded following a comprehensive review of the circumstances that led to the debarment and efforts that have been made by the company to address any outstanding concerns of government agencies. The State Department found PWC’s efforts to be […]

Agreement Amendment Requirements for USML Category XI and XV

November 10, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XV and December 30, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XI. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing […]

Drop-shipping

A common situation that U.S. companies may find themselves in is selling and shipping to a U.S. company, and then being asked to ship directly to a foreign company. This practice, known as drop-shipping, turns the U.S. company into an exporter and with it all the responsibilities of being the U.S. Principal Party in Interest […]

ITAR Canadian Exemption Provision

Prior to utilizing the ITAR Canadian exemption provision to export hardware and technical data related to defense services, exporters must receive a certification that ensures that the end use of the item is allowed under the exemption provision. Additionally, the certification should limit delivery/end use of the defense article being produced directly to an identified […]

Implementing Export Compliance Policies and Procedures

Once your company drafts (or revises) Export Compliance Policies and Procedures, you must ensure you take steps to implement these documents properly and that your company is fully compliant with the procedures outlined in them. Prior to finalizing the Policies and Procedures, companies should ensure there is no conflict between their practices and their written […]