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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 […]

Export Control Reform-USML Category VIII Transition of Agreements and Licenses

On October 15, 2013, many items previously under the jurisdiction of USML Category VIII were transitioned to the jurisdiction of the EAR as part of Export Control Reform. In light of this transitional period, a two year window was designated to allow companies with transitioned items to secure BIS licensing. On October 15, 2015, previously […]

Export Compliance Programs: Policies and Procedures and Technology Control Plans

On December 30th, the new State and Commerce Departments rules regarding military electronics went into effect, transitioning many parts out of the jurisdiction of USML Category XI. As more and more previous ITAR jurisdiction products are controlled by the EAR, it is important to update out of date Export Policies and Procedures and Technology Control […]

DDTC Announce Change for Agreements Affected by ECR

The Directorate of Defense Trade Controls (DDTC) issued an announcement on February 4th stating the following: “Effective immediately, DDTC will make a slight change to the validity dates for certain agreements affected by Export Control Reform. If an agreement contains multiple USML categories, the “relevant final rule” now refers to the last rule impacting any of […]