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Archive for the ‘Export Control’ Category.

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 […]

Export Control Reform Timeline Change

On October 9th, 2015, DDTC amended the previously published Export Control Reform Initiative timeline, allowing exporters to use the full length (48 months) of previously obtained State Department licenses for items that have since transitioned to the EAR. Additionally, exporters are allowed one additional year to secure BIS licensing for agreements that contain either solely […]

Cuba Restrictions Update

On September 21, the Treasury and Commerce Departments issued final rules regarding easing of restrictions on Cuba in light of recent policy changes. The Commerce Department rule revisions included amending the EAR’s Support for the Cuban People license exception, expanding the scale of the exception while still limiting items that are eligible to EAR99 goods […]

License Exception RPL: A Brief Overview

License Exception RPL (Servicing and Replacement of Parts)-EAR Part 740.10- authorizes items under EAR jurisdiction to be exported and reexported, as needed, for the one-for-one replacement of parts, components, accessories, and attachments. To utilize RPL, the items must have been lawfully exported and the original licensing authority must be confirmed by the exporter.  Additionally, the […]