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Archive for the ‘Export Control’ Category.

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 […]

License Exception TMP- Exhibition and Demonstration- An Overview

License Exception TMP §740.9(a)(5) allows for exports, re-exports, and transfers (in-country) of items for exhibition or demonstration.  License Exception TMP requires the exporter to maintain ownership of the items while they are abroad and for the exporter, an employee of the exporter, or the exporter’s designated sales representative to retain “effective control” over the items. […]

AES and ACE

Throughout 2015, the Automated Exporter System (AES) is gradually integrating into the Automated Commercial Environment (ACE) platform.  In June 2015, the Exporter Role deployed, the first type of ACE account. Exporters who do not have an ACE account can sign up on the Census website for access to their shipment records, while those who already […]