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Archive for the ‘Export Control’ Category.

Anti-boycott Restrictions

The Export Administration Regulations require that U.S. persons and U.S. companies refuse to participate in any foreign boycott not sanctioned by the U.S. government.  For enforcement purposes, this primarily focuses on the boycott of Israel by the Arab League. Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, the United Arab Emirates, and Yemen have all been […]

Changes in requirements for International Import Certificate, BIS-711, etc.

On March 13, 2015, the Commerce Department published a rule revising the required support documentation for export license applications.  A major change of this rule was the elimination of the requirement of the International Import Certificate.  Previously, International Import Certificates were required if the items were controlled for national security reasons, were valued at more […]

Additional Sanctions Imposed on Crimea

On January 29th, the Commerce Department issued a final rule amending the EAR in light of recent developments in Russia and Ukraine.  With the exception of food or medicine classified as EAR99, all other items falling within the scope of the EAR will require a license for export or reexport to the Crimea region of […]

U.S. India Bilateral Understanding

On November 8, 2014, President Obama and Prime Minister Singh of India released a joint statement, agreeing to “expand and strengthen the India-U.S. global strategic partnership”. Vowing to work together in key industries like civil space and defense, they agreed that a U.S.-India partnership was not only a positive for their nations but also for […]

Cuban Asset Control Regulations Amendment Announced

On January 16, the Treasury amended the Cuban Asset Control Regulations in light of policy changes announced by President Obama in December. The Cuban Asset Control Regulations, issued in 1963 as the major domestic instrument of enforcement of the Cuban embargo, have been amended on numerous occasions since their creation. Notable amendments in 2009 and […]

Expanded Hong Kong license requirements

On December 23, 2014, the Commerce Department released a rule that expanded license requirements for both exports and re-exports to Hong Kong for products that are controlled for reasons of national security. Before this rule was issued, there was no destination-based license requirement for “certain national security-controlled items”.  Additionally, these items will require an import […]

Reduced Sanctions on Cuba

President Obama announced there will be a reduction in current U.S. import and export sanctions on Cuba today.  Initially, these sanction reductions will result in the lessening of restrictions on Cubans traveling to Cuba to visit relatives and ability to import Cuban cigars into the U.S.   In the weeks ahead, amendments to both OFAC’s Cuban Assets Control Regulations […]

Canadian Exemption Provision

Under 22 CFR 126.5 (b)(1) [i.e. the Canadian Exemption Provision], defense items being exported to Canada may be eligible for this State Department license exemption. To use the Canadian Exemption provision, the Canadian company must have registered through the Canadian Controlled Goods Registration Program.  Additionally, the items must remain in Canada with a Canadian Controlled […]

Government Furnished Equipment

DDTC has waived the §123.22(a)(2) requirement for Government Furnished Equipment (GFE) by U.S. contractors. This section requires that “the applicant, or an agent acting on the applicant’s behalf, must ensure that the U.S. Customs and Border Protection decrements both temporary licenses to show the exit and entry of the hardware.” Under the new policy, contractors […]

Added Restrictions for Venezuela

Additional Restrictions for Venezuela On November 7, the Commerce Department’s Bureau of Industry and Security released a new set of restrictions (79 FR 66288) for exports to Venezuela. In light of the government’s violent oppression of anti-government protests and their attempts to “undermine democratic processes and institutions and thereby constitute an unusual and extraordinary threat […]