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TSU

If you export sales technology as part of your bidding/quoting process, you may be able to utilize the Commerce Department’s Export Administration Regulations’ license exception “Technology and Software Unrestricted (TSU)”. License Exception TSU [§740.13(b)] allows for the export of Commerce jurisdiction technology that is typically part of a quote/bid/offer, per customary business practice. This technology […]

O Canada! (The Blog Edition)

Exporting to Canada can most often done without having to first apply for a license. For products and technical data under the jurisdiction of the State Department, the Canadian exemption provision (22 CFR 126.5) can usually be utilized.  22CFR 126.5(b)(1) should be reviewed by exporters prior to using the Canadian exemption provision as it lists […]

Foreign National Visitors

Access by foreign national visitors to controlled product and technical data should be restricted by U.S. companies. When visitors are identified as foreign nationals at sign in access should be limited to areas of the company’s factory or facility where no export controlled technical data or product can be accessed. If this is not feasible […]

Visitor Log

While the method of how a company captures the information can vary, it is important that all companies with controlled products and technical data require all facility visitors to sign in  upon arrival and that a record of this sign in log is kept. Companies should evaluate visitors’ restrictions based on their citizenship (as well […]

Certification for Suppliers, Vendors, and Subcontractors

Prior to sending controlled technical data to vendors, subcontractors, or suppliers, it is important to ascertain that they are compliant with ITAR and EAR regulations. A certification should be requested from these companies, where they agree to comply with all U.S. export regulations (i.e. ITAR, EAR, etc.). Additionally, vendors/subcontractors/suppliers should certify that they have export […]

Air Shows

If your company will be participating and exhibiting products at Air Shows (Farnborough Air Show, Dubai Air Show, Paris 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 or use of […]

Export Compliance Due Diligence

When considering purchasing a company, either foreign or domestic, it is important to consider the company’s export compliance history. By considering the products/technical data they manufacture and/or export, as well as any controls they have in place for those items, a purchasing company can understand what liabilities they are exposing themselves to by purchasing the […]

Order of Review

Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid. To determine the current classification of an item, exporters should follow DDTC’s Order of Review. Exporters should first consider if the item is listed on the USML and if it falls within the definition of specially designed. If the […]

Export Compliance Guidelines

BIS has issued revised Export Compliance Guidelines ( https://www.bis.doc.gov/index.php/forms-documents/pdfs/1641-ecp/file) to assist exporters in creating and maintaining an effective export compliance program. Sections include training, audits, and requirements for export compliance manuals. BIS sets out regulatory requirements as well as advice on satisfying these requirements.  Please contact our office if you are interested in discussing any of […]

Hong Kong Support Documentation Change

BIS published a rule on January 19th, 2017 amending the support documentation requirements for items being exported or re-exported to Hong Kong.  When the new rule goes into effect on April 19, companies exporting/re-exporting items to Hong Kong must obtain a copy of a valid import license prior to the export/reexport, if the item is […]