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Archive for the ‘Export Compliance Programs’ Category.

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 […]

State Department Registration

Any U.S. company that engages in the manufacture, export or temporary import of defense articles or furnishing of defense services is required to register with the Directorate of Defense Trade Controls (DDTC). Registering allows the government to know who is engaged in these manufacturing industries/activities as well as in export activities.  Registration is also a […]

DDTC Registration

Any U.S. company that engages in manufacture, export or temporary import of defense articles or furnishing of defense services, is required  to register with the Directorate of Defense Trade Controls (DDTC). This information allows the government to know who is engaged in certain manufacturing industries/activities as well as export activities.  DDTC Registration is a requirement […]

Export Compliance Audits

Periodic export compliance audits are an integral aspect of a company’s export compliance program. Audits demonstrate adherence both to a company’s internal controls and to U.S. export laws and regulations, including the Export Administration Regulation and International Traffic in Arms Regulations .  Export compliance audits review export invoices and other export documents to ensure compliance with product […]

Anti-boycott Restrictions

The Export Administration Regulations require that U.S. persons and U.S. companies refuse to participate in any foreign boycott not sanctioned by the U.S. government.  For enforcement purposes, this primarily focuses on the boycott of Israel by the Arab League. Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, the United Arab Emirates, and Yemen have all been […]