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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, […]

Prior Consignee Statement

If your company chooses to utilize BIS license exception STA for eligible exports, it is important that you are using the most current version of the Commerce Department’s Prior Consignee Statement (see below).  The Prior Consignee Statement is to be obtained in writing from the foreign consignee prior to exporting the item. All exports utilizing […]

Export Control Reform: Update and Recap

Over the last 3 years, the State and Commerce Departments have proceeded in issuing proposed and final rules related to Export Control Reform.  Below is the current status of each category and a summary of the requirements for replacement/amendment of licenses for Category VIII/XIX transitioned items related to the termination of the transition period for […]

EAR/ITAR Definitions Rules

On June 3rd, the State and Commerce Departments released final rules revising export related definitions in the EAR and ITAR.  Definitions of export and re-export were harmonized across the two sets of regulations to ease the burden on exporters.  Additionally, definitions of release and retransfer were added to the ITAR, the latter of which is […]

Vietnam Arms Policy Change

On May 23, 2016, the previous policy of denying all DDTC licenses for lethal weapons to Vietnam (i.e. arms and related material) has been terminated. Effective immediately, all ITAR license applications to export or temporarily import defense articles (ITAR controlled items) to Vietnam will be reviewed on a case-by-case basis. A Federal Register notice will […]

Dual Nationals and Third Country Nationals

The State Department sets forth their policy regarding export licensing/agreements and dual-citizens/third-country nationals in two sections of the ITAR. §124.16 allows dual/third country nationals of NATO/EU nations, Australia, Japan, New Zealand, and Switzerland to have access to defense articles/technical data provided for under a TAA/MLA, provided they are an employee of the foreign signatory or […]

Yearly Compliance Requirements

To remain compliant with export control laws and regulations, there are a number of requirements that must be met on a yearly basis. All employees who are involved in export- decision making should receive training on a yearly basis.  Additionally, any new export involved employees should be trained within 90 days of hire and should […]

License Exceptions GBS and CIV

License Exception GBS (Shipments to Country Group B Countries) is applicable for an ECCN if NS is the only reason for control and if it is identified as GBS- YES in the “License Exception” section at the top of the ECCN. This license exception can only be used for the export of items to Country […]