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Archive for the ‘Export Control’ Category.

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 […]

JCPOA

On January 16, 2016, the International Atomic Energy Agency (IAEA) verified that Iran had met its obligations under JCPOA (Joint Comprehensive Plan of Action). In light of this, on January 21, both the Executive Office (through an Executive Order) and OFAC published a revocation of nuclear-related sanctions of Iran. Hundreds of names were removed from […]

Air Shows

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

Requirement to Lodge DDTC licenses with CBP waived

On December 21, 2015, the State Department issued a rule waiving the requirement under 22 CFR 123.22 (a)(1) which required exporters to lodge DDTC licenses with Customs and Border Protection (CBP) before filing in AES or ACE. This change in policy is in anticipation of the implementation of ACE which will provide CBP officials data […]

Canadian Exemption Provision

Exporters who use the Canadian Exemption provision (22 CFR §126.5) for the export of defense services should remember to have a written agreement with the Canadian recipient that satisfies the requirements of 22 CFR §126.5 and the accompanying Supplement No.1.  This agreement should limit delivery of the defense items being produced to DDTC registered company […]

Setting up your DTrade Account

After a DDTC license has been drafted, it must be uploaded via DTrade. Setting up an account with DTrade has several steps that must be followed; otherwise, the license application will be rejected by the State Department.  The first step is purchasing and installing the digital certificate on to the computer which will be used […]

State Department Registration

Any U.S. company that engages in the manufacture, export or temporary import of defense articles or furnishing of defense services is required to register with the Directorate of Defense Trade Controls (DDTC). Registering allows the government to know who is engaged in these manufacturing industries/activities as well as in export activities.  Registration is also a […]

New D-Trade Forms

A new batch of D-Trade forms, including the DS-2032, DSP-5, and DSP-6, were all released earlier this week. Beginning Thursday, November 26, 2015 previous versions of these forms will no longer be accepted.  The revision of these forms will extend the form expiration date. The new batch of forms are available online now via the […]

De Minimis Guidelines

BIS offers an online tool for exporters allowing them to determine if their items made outside of the United States are subject to the EAR in accordance with the de minimis guidelines. If foreign made items incorporate controlled US items or technology, it is important to consider if these items are under the control of […]