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Archive for the ‘Export Control’ Category.

EAR/ITAR Definitions Rules

On June 3rd, the State and Commerce Departments released final rules revising export related definitions in the EAR and ITAR.  Definitions of export and re-export were harmonized across the two sets of regulations to ease the burden on exporters.  Additionally, definitions of release and retransfer were added to the ITAR, the latter of which is […]

Vietnam Arms Policy Change

On May 23, 2016, the previous policy of denying all DDTC licenses for lethal weapons to Vietnam (i.e. arms and related material) has been terminated. Effective immediately, all ITAR license applications to export or temporarily import defense articles (ITAR controlled items) to Vietnam will be reviewed on a case-by-case basis. A Federal Register notice will […]

Dual Nationals and Third Country Nationals

The State Department sets forth their policy regarding export licensing/agreements and dual-citizens/third-country nationals in two sections of the ITAR. §124.16 allows dual/third country nationals of NATO/EU nations, Australia, Japan, New Zealand, and Switzerland to have access to defense articles/technical data provided for under a TAA/MLA, provided they are an employee of the foreign signatory or […]

Yearly Compliance Requirements

To remain compliant with export control laws and regulations, there are a number of requirements that must be met on a yearly basis. All employees who are involved in export- decision making should receive training on a yearly basis.  Additionally, any new export involved employees should be trained within 90 days of hire and should […]

License Exceptions GBS and CIV

License Exception GBS (Shipments to Country Group B Countries) is applicable for an ECCN if NS is the only reason for control and if it is identified as GBS- YES in the “License Exception” section at the top of the ECCN. This license exception can only be used for the export of items to Country […]

Changes to DTrade forms and Agreement Guidelines

On March 31, 2016, DDTC announced that beginning April 15th a new edition of DTrade forms (Version 9.2) will be required.  This will effect DSP-5s, DSP-6s, DSP-61s, DSP-62s, DSP-73s, and DSP-74s. Old versions of the forms will not be accepted starting that date (April 15).   Additionally, on March 29, 2016, DDTC published Revision 4.3 […]

ZTE-Temporary General License

On March 8, 2016, Chinese telecommunications company Zhongxing Telecommunications Equipment (ZTE) was added, along with several related entities, to BIS’ Entity List.  This was a result of ZTE signing contracts in 2012 to ship U.S. made telecom hardware and software to Iran via a series of shell companies, a violation of U.S. Iranian sanctions. Due […]

USML Category XII Proposed Revision

On February 19, the Commerce and State Departments published proposed revisions to USML Category XII and the EAR relating to the control of Fire Control, Lasers, Guidance and Control Equipment.   A previous version of the proposed rule was published on May 5, 2015; due to the comments received however, there was a complete re-draft for […]

Cuba Amendments

On January 27, 2016, new changes to the Cuban Assets Control Regulations (CACR) and the EAR went into effect, continuing the President’s policy of expanding relations with Cuba. Restrictions will be lifted on authorized exports and reexports, allowing U.S. banks to provide financing. This change will not apply for agricultural items and commodities. BIS has […]

Proposed Changes to Military Aircraft and Engine Regulations

  On February 9, the State and Commerce Departments published proposed revisions to the Military Aircraft and Engine regulations.  As stated in the revision by Commerce, these amendments allow for DDTC and BIS to account for “technological developments and practical application issues”. One clarification from BIS is that a note will be added to §740.2 […]