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Government Furnished Equipment

DDTC has waived the §123.22(a)(2) requirement for Government Furnished Equipment (GFE) by U.S. contractors. This section requires that “the applicant, or an agent acting on the applicant’s behalf, must ensure that the U.S. Customs and Border Protection decrements both temporary licenses to show the exit and entry of the hardware.” Under the new policy, contractors […]

Added Restrictions for Venezuela

Additional Restrictions for Venezuela On November 7, the Commerce Department’s Bureau of Industry and Security released a new set of restrictions (79 FR 66288) for exports to Venezuela. In light of the government’s violent oppression of anti-government protests and their attempts to “undermine democratic processes and institutions and thereby constitute an unusual and extraordinary threat […]

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 […]

Export Control Reform

Yesterday marked the one year anniversary of the beginning of Export Control Reform . On October 15, 2013, Export Control went into effect with the transitioning of Category VIII (Aircraft and Related Articles). Thirteen categories have transitioned as of today, with two more, Category XV Spacecraft on November 10th and Category XI Military Electronics on […]

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 […]