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Archive for June 2016

Transition Deadline Approaching for Category VIII Agreements

October 15, 2016 will mark three years from the effective date of the Export Control Reform transition of Categories VIII and XIX. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing secured, by that time.  If all items on your DDTC agreement have transitioned to […]

Temporary General License Extended for ZTE

As previously reported on our Export Blog, on March 8, 2016 Chinese telecommunications company Zhongxing Telecommunications Equipment (ZTE) was added, along with several related entities, to BIS’ Entity List.  This was a result of ZTE signing contracts in 2012 to ship U.S. made telecom hardware and software to Iran via a series of shell companies, […]

Prior Consignee Statement

If your company chooses to utilize BIS license exception STA for eligible exports, it is important that you are using the most current version of the Commerce Department’s Prior Consignee Statement (see below).  The Prior Consignee Statement is to be obtained in writing from the foreign consignee prior to exporting the item. All exports utilizing […]

Export Control Reform: Update and Recap

Over the last 3 years, the State and Commerce Departments have proceeded in issuing proposed and final rules related to Export Control Reform.  Below is the current status of each category and a summary of the requirements for replacement/amendment of licenses for Category VIII/XIX transitioned items related to the termination of the transition period for […]

EAR/ITAR Definitions Rules

On June 3rd, the State and Commerce Departments released final rules revising export related definitions in the EAR and ITAR.  Definitions of export and re-export were harmonized across the two sets of regulations to ease the burden on exporters.  Additionally, definitions of release and retransfer were added to the ITAR, the latter of which is […]