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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 […]

Reduced Sanctions on Cuba

President Obama announced there will be a reduction in current U.S. import and export sanctions on Cuba today.  Initially, these sanction reductions will result in the lessening of restrictions on Cubans traveling to Cuba to visit relatives and ability to import Cuban cigars into the U.S.   In the weeks ahead, amendments to both OFAC’s Cuban Assets Control Regulations […]

Canadian Exemption Provision

Under 22 CFR 126.5 (b)(1) [i.e. the Canadian Exemption Provision], defense items being exported to Canada may be eligible for this State Department license exemption. To use the Canadian Exemption provision, the Canadian company must have registered through the Canadian Controlled Goods Registration Program.  Additionally, the items must remain in Canada with a Canadian Controlled […]

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 […]