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Archive for the ‘Export Compliance Programs’ Category.

Year End Review of Export Compliance Requirements

Another year is coming to a close in a few months making this a good time to review your export compliance program and determine any deficiencies to be addressed prior to year end.   Training: All employees who are involved in export- decision making should receive training on a yearly basis.  Additionally, any new export […]

Schedule B (Statistical Classification of Commodities Exported from the United States) Requirements

A Schedule B number is a 10-digit number used to classify specific commodities on their export from the U.S.  This numeric number qualification of articles is required for the U.S. Government – Census Bureau to gather and report statistics on specific goods exported including: quantity/value, destination country and if the goods are U.S. or foreign origin.    Schedule […]

Who is a U.S. Person?

A U.S. person, in terms of export licensing, is any U.S. citizen, lawful permanent resident (i.e. Green Card holder), or individual who is granted status as a “protected person” under 8 U.S.C. 1324 b(a)(3). It also includes dual-citizens of the U.S. and another country. Foreign Nationals are non-U.S. persons (including those with work authorizations). Additionally, […]

Implementing Export Compliance Policies and Procedures

Once your company drafts (or revises) Export Compliance Policies and Procedures, you must ensure you take steps to implement these documents properly and that your company is fully compliant with the procedures outlined in them. Prior to finalizing the Policies and Procedures, companies should ensure there is no conflict between their practices and their written […]

Restricted Parties Screening

A key component to every company’s export compliance program should be screening of the U.S. government export sanctioned lists prior to shipment. Companies may choose to screen the lists prior to accepting an order, but that does not negate their responsibility to screen prior to shipment as well as parties may have been added after […]

Certification for Suppliers, Vendors, and Subcontractors

Prior to sending controlled technical data to vendors, subcontractors, or suppliers, it is important to ascertain that they are compliant with ITAR and EAR regulations. A certification should be requested from these companies, where they agree to comply with all U.S. export regulations (i.e. ITAR, EAR, etc.). Additionally, vendors/subcontractors/suppliers should certify that they have export […]

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 […]

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 […]

Foreign Company Requirements for Receipt of U.S. Export Controlled Commodities/Technical Data

A common question asked is what are the responsibilities for foreign parties who are in receipt of U.S. export controlled commodities and technical data. The U.S. exporter needs to know these requirements to not only assist their foreign customers with their compliance to U.S. export laws and regulation, but also for the U.S. exporter to […]

ACE Transition

Since the Obama administration published Executive Order 13659 in February 2014, there has been a gradual transition to a “single window” for the input of export data electronically. This streamlining was meant to put all required data for all federal agencies in one place, and allow for the expediting of shipments and reduction of redundant […]