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Archive for November 2017

U.S. Export Controls for the Commercial Space Industry

The 2nd edition of the “U.S. Export Controls for the Commercial Space Industry” was jointly published this month by Commerce’s Office of Space Commerce and the FAA’s Office of Commercial Space Transportation. This guide assists manufacturers and exporters in the commercial space industry with a variety of export related tasks, such as determining the jurisdiction […]

Cote d’Ivoire Sanctions Removed

On November 13, 2017, OFAC removed the Cote d’Ivoire Sanctions Regulations from the Federal Register. This was a product of the termination of the national emergency by President Obama in September 2016. A national emergency had been declared in regards to Cote d’Ivoire in February 2006, and the sanction program for the country was implemented […]

De Minimis

For items under the U.S. Commerce Department jurisdiction, the EAR has a set of rules for determining if a foreign made commodity/software/technology incorporates enough U.S. origin controlled content to still be under EAR jurisdiction. For a non- 600 series/9×515/”see through carve out” (see below) item going to Country Group E:1 and for items classified as […]

Direct Product Rule

EAR §736.2 (b)(3) advises companies regarding the circumstances when non U.S. made products will require a Commerce license (called the “direct product rule”). For items that are not 600 series (or 9×515) and are not U.S. made, a license (or use of a license exception) will still be required to export abroad if the U.S. […]