Tel: (860) 651-8544

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 […]

Letter of Intent/End Use Statement

It is best practice before you export an item to receive a Letter of Intent (LOI) or End Use Statement (EUS) from your foreign customer. These statements are required for State Department (DDTC) licenses and recommended for Commerce Department (BIS) licenses. A LOI or EUS must identify the larger system that the exported item will […]

Category XII Transition Final Rules Published

On October 12, 2016, the State and Commerce Departments published final rules amending USML Category XII: Fire Control, Laser, Imaging, and Guidance Equipment. The final rule will be effective on December 31, 2016.  In the revised Category XII, certain paragraphs define items as defense articles (and thus include them on the USML) based on if […]

DDTC Company Visit Program

DDTC Company Visit Program The State Department’s Office of Defense Trade Controls Compliance (DTCC) relaunched their Company Visit Program (CVP) this year. This program provides for visits by DTCC compliance personnel, or other representatives of the Directorate of Defense Trade Controls (DDTC), to various DDTC registered entities, as well as other parties involved in ITAR […]

Export Training

Regular export training of export involved employees on U.S. Export Licensing and Compliance is an important aspect of any Export Compliance program. Export Policies and Procedures should reference the training schedule (ex. annual, periodic), as well as requirements for new employees to be trained. Training can be done by qualified internal personnel  or outside experts in […]

ACE Transition

Since the Obama administration published Executive Order 13659 in February 2014, there has been a gradual transition to a “single window” for the input of export data electronically. This streamlining was meant to put all required data for all federal agencies in one place, and allow for the expediting of shipments and reduction of redundant […]

DDTC Agreement Guidelines Revision

On September 1, 2016, the DDTC Guidelines for Preparing Agreements (Revision 4.4) went into effect. The revised guidelines take into account the revised definitions for export, reexport, and retransfer, as described in the State Department Rule published on June 3.  This rule harmonized definitions of the above words and also went into effect September 1st.   […]