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USML Category XII Proposed Revision-BIS Guidance on Infrared Detection Items

On May 5th, BIS published a proposed rule for the revision of USML Category XII.  This rule would result in the creation of new ECCNs 6×615 and 7×611 for military fire control, range finder, optical and guidance items. Additionally, controls on certain infrared detection items were increased.  On June 16th, BIS published a document providing […]

USMIL Final Rule Published

USMIL final rule published as part of Export Control Reform firearms components no longer controlled On May 21st, the final rule to remove unnecessary items from the United States Munitions Import List (USMIL), under the jurisdiction of the Bureau of Alcohol, Tobacco, Firearms, and Explosives, was published. This rule finalized an interim rule published on March […]

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: […]

Category XII Proposed Rule Changes

On May 5th, the State and Commerce Departments released Category XII proposed rule changes.  If propose, some items currently under the jurisdiction of USML Category XII (Fire Ranger, Ranger Finder, and Optical and Guidance Equipment, etc.)  will transition to the Commerce Department.  Less items will be affected in this transition than in past category transitions (i.e. Category VIII). For some items, […]

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 […]

DTCL Reorganization

As of April 20th, there was a reorganization of the Office of Defense Trade Control Licensing (DTCL).  There will now be four operational divisions instead of the previous seven, with each handling more USML categories. The four current divisions are: Space, Missile, and Sensor Systems; Electronic and Training Systems; Sea, Land, and Air Systems, and […]

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 […]