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Archive for the ‘Export Control’ Category.

Reminder-PW Canada statutory debarment

  Recently we have gotten a lot of questions about the Pratt Whitney Canada 2012 statutory debarment. Following a June 28, 2012 guilty plea for violations of ITAR and Arms Export Control Act (AECA), the State Department issued a statutory debarment against Pratt Whitney Canada. This debarment would only affect PW Canada, not any other […]

New Russia License Requirements

  License requirements for certain ECCNs for “military end use” were extended to include both the PRC and Russia.  Supplement No. 2 to Part 744 of the EAR provides a list of the specific ECCNs requiring approved licenses for export to the PRC and Russia for military end use (as that term is defined in […]

BIS License Exceptions

There are several general BIS license exceptions that may be used in lieu of obtaining a license. To use an exception, none of the 10 restrictions that are applicable to all BIS license exceptions must be present (EAR §740.2). These include many items controlled because they are missile technology controlled items and goods being exported […]

Restricted Parties Screening

Restricted Parties List Screening   It is important for a company to do a restricted parties list screening upon the receipt and acceptance of each export order. This will allow a company to avoid involvement in initiating an export transaction with an U.S. export restricted party.   There are several lists to search that are frequently updated. A […]

Air Shows

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

Export Policies and Procedures

Policies and Procedures   As the U.S. government is becoming more aggressive in export compliance investigations, it is recommended that companies have in place export policies and procedures to ensure employee’s compliance with U.S. export laws and regulations. In light of Export Control Reform, companies with older Policies and Procedures enacted may find these out of date and no […]

Russia Sanctions

Russia Sanctions-An American Response to the Crises in Crimea On April 28, the Commerce Department’s Bureau of Industry and Security (BIS) began a policy of denying high-tech export licenses for goods destined for Russia or Crimea if the goods were judged by BIS to potentially help Russia’s defense capabilities. This was part of a larger […]

Spacecraft Licensing Changes

Many  Spacecraft Items Move from USML Cat. XV to EAR 9X515 On May 13, 2014 the Commerce Department released the interim final revisions to USML Category XV-Spacecraft and related items. As of November 10, many items previously controlled by the State Department in the spacecraft USML category will now be controlled by the Commerce Department’s […]

Cloud Application Licensing

DDTC suggests that with “sufficient means” cloud application licensing may not be necessary, provided the recipient is a US person employed by US government or corporation The State Department posted a response to a company’s recent post and subsequent clarification regarding a State Department advisory opinion. In the original opinion, the DDTC said that tokenization […]

International Import Certificate Proposed Changes

Proposed Changes to the International Import Certificate Requirements A proposed revision to the Export Administration Regulations (EAR) would eliminate the need for exporters to secure an International Import Certificate before getting a license. This proposed rule change recognizes the decreased utility of the IIC (as most other nations no longer require exporters to secure them) […]