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Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid.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

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 […]