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Traveling with Technical Data

Prior to international travel, all employees should be made aware of the limitations of what technical data can be brought with them and what can be shared with foreign persons. To make transit smoother, it is recommended that all employees traveling internationally carry an export statement letter on their person, in case they are stopped […]

Export Reminders for the Start of 2018

As 2018 begins, there are a number of things that exporters should remember to do on a yearly basis to make sure they are in compliance with U.S. export laws and regulations.   Training: All export- decision making employees should receive training on a yearly basis.  Additionally, any new export involved employees should be trained […]

Red Flags

  BIS cautions regarding certain scenarios that require an extra layer of due diligence on the part of an exporter during an export transaction when determining whether to enter into the transaction. This list is not exhaustive, but is meant to illustrate certain times when the exporter cannot rely solely on the information provided by […]

DDTC agreements

In addition to issuing export licenses, U.S. State Department’s DDTC also reviews and approves agreements between U.S. companies and foreign companies that involve the transfer of technical data and/or distribution rights of hardware.  Agreements in themselves do not authorize hardware exports but exports of hardware can be covered in the scope of the agreement and […]

U.S. Export Controls for the Commercial Space Industry

The 2nd edition of the “U.S. Export Controls for the Commercial Space Industry” was jointly published this month by Commerce’s Office of Space Commerce and the FAA’s Office of Commercial Space Transportation. This guide assists manufacturers and exporters in the commercial space industry with a variety of export related tasks, such as determining the jurisdiction […]

Cote d’Ivoire Sanctions Removed

On November 13, 2017, OFAC removed the Cote d’Ivoire Sanctions Regulations from the Federal Register. This was a product of the termination of the national emergency by President Obama in September 2016. A national emergency had been declared in regards to Cote d’Ivoire in February 2006, and the sanction program for the country was implemented […]

De Minimis

For items under the U.S. Commerce Department jurisdiction, the EAR has a set of rules for determining if a foreign made commodity/software/technology incorporates enough U.S. origin controlled content to still be under EAR jurisdiction. For a non- 600 series/9×515/”see through carve out” (see below) item going to Country Group E:1 and for items classified as […]

Direct Product Rule

EAR §736.2 (b)(3) advises companies regarding the circumstances when non U.S. made products will require a Commerce license (called the “direct product rule”). For items that are not 600 series (or 9×515) and are not U.S. made, a license (or use of a license exception) will still be required to export abroad if the U.S. […]

DOD – Military Critical Technical Data- Joint Certification Program (JCP)

For a U.S. company to be permitted access to U.S. Department of Defense (DOD) or Canadian Department of National Defense (DND) technical data that has been qualified as Military Critical Technology Data, the company must be certified (registered) under the Joint Certification Program of DOD or DND. The U.S. company’s certification is completed with DOD […]

Revocation of Certain Sanction Regarding Sudan

Effective October 12, 2017, the Office of Foreign Assets Control is revoking many of the sanctions on Sudan.  Sudan, however, continues be included on OFAC’s and BIS’s lists as a State Sponsor of Terrorism (SST) and applicable restrictions pertain. With the revocation of existing OFAC sanctions exports to Sudan are permissible for export by use […]