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Archive for the ‘Export Control’ Category.

Automated Export System Shipment Reminders

If your company exports goods valued at more than $2,500 per Schedule B number to anywhere other than Canada or goods that require an export license, the regulations require that you submit the Electronic Export Information (EEI) through AES (Automated Export System). AES filing is exempt for shipments of BIS controlled .y. paragraph 9×515 or “600-series” items with a value of $2,500 […]

New Russia Sanctions to be Imposed in August 2018 by the U.S. Department of State

Chemical and Biological Weapons (CBW) Sanctions which will be imposed on Russia by the U.S. State Department on or about August 22, 2018 include the imposition of a “presumption of denial” for export licenses for US origin national security-sensitive goods and technology controlled by the US Department of Commerce’s Export Administration Regulations to any Russian […]

Avoid Doing Restricted Business with North Korea or Other Sanctioned Countries

The U.S. State Department has issued an alert to companies who may be doing business with North Korea and are unaware of the fact that North Korea is masking and misrepresenting services and goods produced in North Korea and exported under a different name, or providing service and manufacturing products by a company outside of […]

Foreign National Employee License Requirements

If you have foreign national employees, it may be necessary to secure BIS or DDTC licensing for those employee to access controlled technical data and/or product.  Foreign national employees are employees who are neither U.S. citizens, lawful permanent residents (i.e. Green Card holder), nor an individual who is granted status as a “protected person” under 8 U.S.C. 1324b(a)(3). […]

Export Licensing Requirements for Foreign Trade Shows

If your company will be participating and exhibiting products at Air Shows or Trade Shows, it is important that any military/defense products, including parts/components, are not forwarded/exported or taken with company employees to the trade show without required State Department or Commerce Department licensing authority or use of a license exemption/exception. There is also a […]

The Import Side of Export Compliance

Important issues to address when exporting product from the U.S. include ensuring that appropriate export licensing authority, including a license or applicable exception/exemption is provided for that export sale; and that shipment certifications are obtained. There are, however, other important considerations and provisioning that should be addressed and provided for with regards to the return […]

International Air Shows- Export Compliance Considerations

Your yearly reminder regarding Air Shows: If your company will be participating and exhibiting products at Air Shows (Berlin Air Show, Eurasia Air Show, Farnborough Air Show, etc.) it is important that any military/defense, including parts/components, or other ITAR/EAR controlled products, are not forwarded/exported or taken with company employees to the air show without required […]

Minor Amendments to DDTC Agreements

Some changes to agreements (TAAs, MLAs, and WDAs) do not require approval by DDTC before going into effect. Changes that can be made via minor amendment are limited to revisions that do not change the scope of the agreement. DDTC has an inclusive list of what changes are allowable by minor amendment; these include (but […]

South Sudan Sanctions-Update

On February 14, 2018 the Department of State (DDTC) amended the International Traffic in Arms Regulations (ITAR) to prohibit exports, imports, and sales to and from South Sudan.  DDTC has implemented a policy of denial on the export of defense articles and defense services, with certain specific exceptions which include exports for United Nations operations […]

Destination Control Statement

As a reminder, the stipulated Destination Control Statement is required to be printed on all commercial invoices for shipments of all ITAR and most EAR jurisdiction items. Items classified as EAR99 or exported under license exception BAG or GFT will continue to not require a Destination Control Statement.  The Destination Control Statement for both State/Commerce […]