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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.   […]

Harmonization of Destination Control Statement

On August 17, the State and Commerce Departments issued notices finalizing the harmonization of the destination control statement between the two departments that will go into effect on November 15. At the present time, the Commerce and the State Department both require Destination Control Statements to be printed on various export documents, but the text […]

Decrementing BIS Licenses in AES

On July 28, AES began decrementing BIS licenses and notifying exporters. Exporters who report exports against a BIS license will get a series of Informational Messages through AES to assist them in keeping track of the remaining value of their license. These messages include notification when the value of the license has been exceeded/met by […]

Category XIV (toxicological agents) and XVIII(directed energy weapons) Final Rule Published

On July 28, 2016 the Commerce and State Departments issued notices amending Category XIV (toxicological agents) and XVIII (directed energy weapons).  This transition will go into effect on December 21, 2016.  Category XIV, using guidance from the Department of Health and Human Services and Department of Agriculture, establishes a list of Tier 1 pathogens and […]

Export Shipment Compliance Requirements

When shipping and exporting an item, either licensable or non-licensable, there are certain steps you should take to make sure you are in compliance with U.S. export laws and regulations. First, before shipment, the exporter should check to make sure no party to the transaction is on any U.S. government restricted party list. You must […]

Foreign National Licensing

If you have foreign national employees, it may be necessary to secure BIS or DDTC licensing for those employee to access controlled technical data and/or product.  Foreign national employees are employees who are neither U.S. citizens, lawful permanent residents (i.e. Green Card holder), nor an individual who is granted status as a “protected person” under 8 U.S.C. 1324b(a)(3). […]

Transition Deadline Approaching for Category VIII Agreements

October 15, 2016 will mark three years from the effective date of the Export Control Reform transition of Categories VIII and XIX. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing secured, by that time.  If all items on your DDTC agreement have transitioned to […]

Temporary General License Extended for ZTE

As previously reported on our Export Blog, on March 8, 2016 Chinese telecommunications company Zhongxing Telecommunications Equipment (ZTE) was added, along with several related entities, to BIS’ Entity List.  This was a result of ZTE signing contracts in 2012 to ship U.S. made telecom hardware and software to Iran via a series of shell companies, […]