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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 In light of Export Control Reform, companies with older Policies and Procedures enacted may find these out of date and no […]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 […]

Spacecraft Licensing Changes

Many  Spacecraft Items Move from USML Cat. XV to EAR 9X515 On May 13, 2014 the Commerce Department released the interim final revisions to USML Category XV-Spacecraft and related items. As of November 10, many items previously controlled by the State Department in the spacecraft USML category will now be controlled by the Commerce Department’s […]

Cloud Application Licensing

DDTC suggests that with “sufficient means” cloud application licensing may not be necessary, provided the recipient is a US person employed by US government or corporation The State Department posted a response to a company’s recent post and subsequent clarification regarding a State Department advisory opinion. In the original opinion, the DDTC said that tokenization […]

International Import Certificate Proposed Changes

Proposed Changes to the International Import Certificate Requirements A proposed revision to the Export Administration Regulations (EAR) would eliminate the need for exporters to secure an International Import Certificate before getting a license. This proposed rule change recognizes the decreased utility of the IIC (as most other nations no longer require exporters to secure them) […]