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Archive for the ‘Export Compliance Programs’ Category.

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 […]

Revisions to Cuba Export Restrictions

The Bureau of Industry of Security (BIS) and Office of Foreign Assets Control (OFAC) announced on March 16, 2016 amendments to regulations restricting trade with Cuba in response to the President’s policy. These changes permit the following trade activities, previously restricted.   Travel to Cuba – (People to People Educational) by U.S. Persons to Cuba […]

DOD Distribution Statements

The Defense Department utilizes a series of Distribution Statements for technical data that describe the level of distribution authorized. These statements are labeled A-F and X.  Statement A is the least restrictive, signifying the data is approved for unlimited public distribution and Statement F the most restrictive which limits “further dissemination only as directed by […]

Export Classification/Jurisdiction

Exporting is not the only reason to determine the U.S. Export classification/jurisdiction of a company’s items. The need to restrict controlled technical data from foreign nationals should be a major consideration for all companies.  This need may come in many forms, from employing foreign nationals, inquiries from foreign companies requesting product information, or foreign national […]