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Archive for the ‘Export Control’ Category.

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 […]

South Sudan Sanctions

On February 2, 2018, the State Department announced they will be executing limitations on the export of defense articles and services to South Sudan. This announcement is in response to the worsening humanitarian crises in South Sudan, with killings of aid workers on the rise, in addition to a worsening famine and refugee crises.  The State Department […]

Annual Reports of Sale

Annual Reports of Sale are required to be submitted to DDTC for Warehouse and Distribution Agreements and Manufacturing License Agreements. These report should only include what was manufactured (MLA) or distributed (WDA) from the foreign party, not what was exported to the foreign party from the U.S. party. Only actual transfers of hardware by the […]

JCPOA Statement Issued

On January 12, 2018, the Trump Administration released a statement regarding JCPOA, the international agreement regarding limiting Iran’s nuclear capabilities. While not pulling the US out of the agreement at this time, it outlined required changes that must be made in a supplemental agreement for the US to remain a party to JCPOA. This includes […]

Traveling with Technical Data

Prior to international travel, all employees should be made aware of the limitations of what technical data can be brought with them and what can be shared with foreign persons. To make transit smoother, it is recommended that all employees traveling internationally carry an export statement letter on their person, in case they are stopped […]

Red Flags

  BIS cautions regarding certain scenarios that require an extra layer of due diligence on the part of an exporter during an export transaction when determining whether to enter into the transaction. This list is not exhaustive, but is meant to illustrate certain times when the exporter cannot rely solely on the information provided by […]

DDTC agreements

In addition to issuing export licenses, U.S. State Department’s DDTC also reviews and approves agreements between U.S. companies and foreign companies that involve the transfer of technical data and/or distribution rights of hardware.  Agreements in themselves do not authorize hardware exports but exports of hardware can be covered in the scope of the agreement and […]

Cote d’Ivoire Sanctions Removed

On November 13, 2017, OFAC removed the Cote d’Ivoire Sanctions Regulations from the Federal Register. This was a product of the termination of the national emergency by President Obama in September 2016. A national emergency had been declared in regards to Cote d’Ivoire in February 2006, and the sanction program for the country was implemented […]