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Archive for the ‘Export Control’ Category.

Cuba: AT Restrictions removed

On July 22nd, the Commerce Department published a rule implementing the May 29th decision to remove Cuba from the State Sponsor of Terrorism list. While Cuba is still subject to a statutory embargo, it is no longer subject to anti-terrorism (AT) level of controls. Due to the statutory embargo all items under the jurisdiction of […]

Iranian Sanctions Relief

On June 5th, the Federal Register published a State Department provision regarding the “limited, temporary and targeted sanctions relief to Iran” as a consequence of the agreement regarding the nuclear program reached with Iran in April.  The State Department will waive certain sanctions in the hopes of continuing to make future progress negotiating and fulfilling […]

Federal Register Updates- Wassenaar Arrangement, Crimea exception, etc.

  May 20: 80 FR 28853- BIS proposes to implement 2013 Wassenaar Arrangement, in regards to cybersecurity items, intrusion software, and related software. ECCNS 4A005 and 4D004 would be added to control these items. A license would be required for export/reexport/transfer for all countries except Canada, which would be an increase in control. May 21: […]

Merger, Acquisition & Divestiture

If you are a State Department registered company, it is important to consider the State Department requirements in the event your company engages in a merger or acquisition. If the sale or acquisition involves an ITAR registered entity or business (i.e. product line) of an entity, the burden is on the seller to provide advance notification […]

Export Compliance Audits

Periodic export compliance audits are an integral aspect of a company’s export compliance program. Audits demonstrate adherence both to a company’s internal controls and to U.S. export laws and regulations, including the Export Administration Regulation and International Traffic in Arms Regulations .  Export compliance audits review export invoices and other export documents to ensure compliance with product […]

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 […]