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Archive for the ‘Export Compliance Programs’ Category.

Countering America’s Adversaries Through Sanctions Act of 2017- Additional Parties and Sanctions Added

On September 29, 2017, the President delegated the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), which became effective July 28, 2017, to the authority of the Secretary of State.  Additional parties and sanctions were just added on September 20, 2018. Under the provisions of this Act sanctions were imposed on certain persons (individuals and entities) […]

Company Security Requirements- U.S. Government Including DOD Controlled Information

Information that has been provided to a company directly by a U.S. Government (USG) agency, including DOD, or through another company must be controlled in accordance to USG stipulated controls and safeguards to protect this information from unauthorized access. The National Industrial Security Program Operations Manual (NISPOM) provides specific requirements, restrictions, and other safeguards to […]

Export Reminders for the Start of 2018

As 2018 begins, there are a number of things that exporters should remember to do on a yearly basis to make sure they are in compliance with U.S. export laws and regulations.   Training: All export- decision making employees should receive training on a yearly basis.  Additionally, any new export involved employees should be trained […]

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 […]