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Archive for November 2017

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. […]