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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 As more and more previous ITAR jurisdiction products are controlled by the EAR, it is important to update out of date Export Policies and Procedures and Technology Control […]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 […]

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 […]

ITAR Category XI Transition

On December 30, ITAR Category XI (Military Electronics) will be transitioning to the EAR. Many items previously under the jurisdiction of the State Department will now be a part of the Commerce Department’s 600 series.  These items will require a Commerce Department license, if they are not eligible for the use of a license exception.  As not all […]