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Archive for February 2017

Export Compliance Due Diligence

When considering purchasing a company, either foreign or domestic, it is important to consider the company’s export compliance history. By considering the products/technical data they manufacture and/or export, as well as any controls they have in place for those items, a purchasing company can understand what liabilities they are exposing themselves to by purchasing the […]

Order of Review

Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid. To determine the current classification of an item, exporters should follow DDTC’s Order of Review. Exporters should first consider if the item is listed on the USML and if it falls within the definition of specially designed. If the […]

Export Compliance Guidelines

BIS has issued revised Export Compliance Guidelines ( https://www.bis.doc.gov/index.php/forms-documents/pdfs/1641-ecp/file) to assist exporters in creating and maintaining an effective export compliance program. Sections include training, audits, and requirements for export compliance manuals. BIS sets out regulatory requirements as well as advice on satisfying these requirements.  Please contact our office if you are interested in discussing any of […]

Hong Kong Support Documentation Change

BIS published a rule on January 19th, 2017 amending the support documentation requirements for items being exported or re-exported to Hong Kong.  When the new rule goes into effect on April 19, companies exporting/re-exporting items to Hong Kong must obtain a copy of a valid import license prior to the export/reexport, if the item is […]

Updating DDTC after Merger or Acquisition

As a reminder, companies who are registered with DDTC are required to notify DDTC of any mergers, acquisition or divestitures of ITAR manufacturing/exporting subsidiaries or affiliate. If the transaction does not involve a sale to a foreign party, DDTC must be notified within 5 days of the sale. Both buyers and sellers are required to […]