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Archive for the ‘Export Control’ Category.

Foreign National Visitors

Access by foreign national visitors to controlled product and technical data should be restricted by U.S. companies. When visitors are identified as foreign nationals at sign in access should be limited to areas of the company’s factory or facility where no export controlled technical data or product can be accessed. If this is not feasible […]

Visitor Log

While the method of how a company captures the information can vary, it is important that all companies with controlled products and technical data require all facility visitors to sign in  upon arrival and that a record of this sign in log is kept. Companies should evaluate visitors’ restrictions based on their citizenship (as well […]

Air Shows

If your company will be participating and exhibiting products at Air Shows (Farnborough Air Show, Dubai Air Show, Paris 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 or use of […]

Order of Review

Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid. To determine the current classification of an item, exporters should follow DDTC’s Order of Review. Exporters should first consider if the item is listed on the USML and if it falls within the definition of specially designed. If the […]

Export Compliance Guidelines

BIS has issued revised Export Compliance Guidelines ( https://www.bis.doc.gov/index.php/forms-documents/pdfs/1641-ecp/file) to assist exporters in creating and maintaining an effective export compliance program. Sections include training, audits, and requirements for export compliance manuals. BIS sets out regulatory requirements as well as advice on satisfying these requirements.  Please contact our office if you are interested in discussing any of […]

Hong Kong Support Documentation Change

BIS published a rule on January 19th, 2017 amending the support documentation requirements for items being exported or re-exported to Hong Kong.  When the new rule goes into effect on April 19, companies exporting/re-exporting items to Hong Kong must obtain a copy of a valid import license prior to the export/reexport, if the item is […]

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 […]

Audits

Export compliance audits and reviews should be done on a periodic basis and are a fundamental aspect of a complete export compliance program. Audits should survey both a company’s adherence to their own internal policies and procedures, as well as governmental regulations (i.e. ITAR, EAR). Audits should include discussions and reviews of documentation from various functional […]

Letter of Intent/End Use Statement

It is best practice before you export an item to receive a Letter of Intent (LOI) or End Use Statement (EUS) from your foreign customer. These statements are required for State Department (DDTC) licenses and recommended for Commerce Department (BIS) licenses. A LOI or EUS must identify the larger system that the exported item will […]

Category XII Transition Final Rules Published

On October 12, 2016, the State and Commerce Departments published final rules amending USML Category XII: Fire Control, Laser, Imaging, and Guidance Equipment. The final rule will be effective on December 31, 2016.  In the revised Category XII, certain paragraphs define items as defense articles (and thus include them on the USML) based on if […]