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Archive for the ‘EAR Compliance’ Category.

Special Comprehensive Licenses (SCL) Removed from EAR

On August 26th, the EAR was amended to remove Special Comprehensive Licenses (SCL) effective September 25, 2015. The major reason for this change was that BIS officials believed that SCLs were no longer necessary in light of Export Control Reform.  It had been concluded that individual licenses would offer exporters substantially the same benefits than […]

License Exception GOV: Overview

License Exception GOV (§740.11) authorizes exports, re-exports, and in- country transfer of eligible items to U.S. government persons and agencies, agencies of “cooperating governments”, and international inspections under the International Space Station and the Chemical Weapons Convention.   To be eligible for use of license exception GOV, the items must either be for the personal use […]

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 […]

Changes in requirements for International Import Certificate, BIS-711, etc.

On March 13, 2015, the Commerce Department published a rule revising the required support documentation for export license applications.  A major change of this rule was the elimination of the requirement of the International Import Certificate.  Previously, International Import Certificates were required if the items were controlled for national security reasons, were valued at more […]

Additional Sanctions Imposed on Crimea

On January 29th, the Commerce Department issued a final rule amending the EAR in light of recent developments in Russia and Ukraine.  With the exception of food or medicine classified as EAR99, all other items falling within the scope of the EAR will require a license for export or reexport to the Crimea region of […]

BIS License Exceptions

There are several general BIS license exceptions that may be used in lieu of obtaining a license. To use an exception, none of the 10 restrictions that are applicable to all BIS license exceptions must be present (EAR §740.2). These include many items controlled because they are missile technology controlled items and goods being exported […]

Air Shows

Air Shows If your company will be participating and exhibiting products at Air Shows (Farnborough Air Show, Paris Air Show, ILA Berlin Air Show, etc.) it is important that any military/defense products, including parts/components, are not forwarded/exported or taken with company employees to the air show without required State Department or Commerce Department licensing authority […]

Spacecraft Licensing Changes

Many  Spacecraft Items Move from USML Cat. XV to EAR 9X515 On May 13, 2014 the Commerce Department released the interim final revisions to USML Category XV-Spacecraft and related items. As of November 10, many items previously controlled by the State Department in the spacecraft USML category will now be controlled by the Commerce Department’s […]