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Archive for July 2015

License Exception GOV: Overview

License Exception GOV (§740.11) authorizes exports, re-exports, and in- country transfer of eligible items to U.S. government persons and agencies, agencies of “cooperating governments”, and international inspections under the International Space Station and the Chemical Weapons Convention.   To be eligible for use of license exception GOV, the items must either be for the personal use […]

Cuba: AT Restrictions removed

On July 22nd, the Commerce Department published a rule implementing the May 29th decision to remove Cuba from the State Sponsor of Terrorism list. While Cuba is still subject to a statutory embargo, it is no longer subject to anti-terrorism (AT) level of controls. Due to the statutory embargo all items under the jurisdiction of […]

Export Control Reform: Update and Recap

Export Control Reform: Update and Recap   Over the last 20 months, the State and Commerce Departments have published final rules for the transition of 15 categories.  Additionally, 3 more have had proposed rules published that are expected to be published in the final form in the coming months.  A few especially pertinent transition dates […]

Temporary Change to ITAR USML Category XI

On July 2nd, the State Department announced a temporary change in ITAR USML Category XI.  Due to confusing language prior to the change, some exporters did not realize that certain intelligence analytics software remained under the jurisdiction of ITAR USML Category XI. To end this confusion, a temporary revision to Category XI(b) was enacted on […]