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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Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid.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 […]

Updating DDTC after Merger or Acquisition

As a reminder, companies who are registered with DDTC are required to notify DDTC of any mergers, acquisition or divestitures of ITAR manufacturing/exporting subsidiaries or affiliate. If the transaction does not involve a sale to a foreign party, DDTC must be notified within 5 days of the sale. Both buyers and sellers are required to […]

Spacecraft Regulations Revisions

DDTC and BIS released revisions to the Spacecraft regulations (USML Category XV) on January 10, 2017. The revised regulations will become effective on January 15th. Four categories of changes to the regulations were identified, including  (a) change in ITAR standards of control regarding aperture size for spacecraft; (b) the migration of the James Webb Space […]

Export Reminders for the Start of 2017

As the New Year begins, there are a few things to keep in mind to make sure you are in compliance with changing export regulations.  Revisions to USML Categories VIII, XII, XIII, XIV, XV, XVIII, and XIX (as well as associated CCL ECCNs) that have been finalized and published between July and November of 2016  will […]

Foreign Company Requirements for Receipt of U.S. Export Controlled Commodities/Technical Data

A common question asked is what are the responsibilities for foreign parties who are in receipt of U.S. export controlled commodities and technical data. The U.S. exporter needs to know these requirements to not only assist their foreign customers with their compliance to U.S. export laws and regulation, but also for the U.S. exporter to […]

Audits

Export compliance audits and reviews should be done on a periodic basis and are a fundamental aspect of a complete export compliance program. Audits should survey both a company’s adherence to their own internal policies and procedures, as well as governmental regulations (i.e. ITAR, EAR). Audits should include discussions and reviews of documentation from various functional […]

USML Category VIII and XIX Revision

On November 21, Commerce and State published final rules revising and clarifying the items to be included in USML VIII and XIX (Military Aircraft/Gas Turbine Engines). These rules finalize proposed revisions that were published in February 2016, and will go into effect on December 31, 2016. The purpose of these revisions are to account for […]

New Destination Control Statement to be required on November 15th

As a reminder, the harmonized Destination Control Statement will be required by the State and Commerce Departments for export shipments starting on November 15.  Additionally, following implementation of this revision, the Destination Control Statement will only be required on commercial invoices (not on bill of lading, air waybill, etc. as is currently required). Items classified as […]