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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) […]