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Archive for the ‘Export Compliance Programs’ Category.

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 […]

Export Compliance Programs: Policies and Procedures and Technology Control Plans

On December 30th, the new State and Commerce Departments rules regarding military electronics went into effect, transitioning many parts out of the jurisdiction of USML Category XI. As more and more previous ITAR jurisdiction products are controlled by the EAR, it is important to update out of date Export Policies and Procedures and Technology Control […]

Export Control Reform

Yesterday marked the one year anniversary of the beginning of Export Control Reform . On October 15, 2013, Export Control went into effect with the transitioning of Category VIII (Aircraft and Related Articles). Thirteen categories have transitioned as of today, with two more, Category XV Spacecraft on November 10th and Category XI Military Electronics on […]

Restricted Parties Screening

Restricted Parties List Screening   It is important for a company to do a restricted parties list screening upon the receipt and acceptance of each export order. This will allow a company to avoid involvement in initiating an export transaction with an U.S. export restricted party.   There are several lists to search that are frequently updated. A […]