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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 […]

Changes to DTrade forms and Agreement Guidelines

On March 31, 2016, DDTC announced that beginning April 15th a new edition of DTrade forms (Version 9.2) will be required.  This will effect DSP-5s, DSP-6s, DSP-61s, DSP-62s, DSP-73s, and DSP-74s. Old versions of the forms will not be accepted starting that date (April 15).   Additionally, on March 29, 2016, DDTC published Revision 4.3 […]

ZTE-Temporary General License

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, a violation of U.S. Iranian sanctions. Due […]

Revisions to Cuba Export Restrictions

The Bureau of Industry of Security (BIS) and Office of Foreign Assets Control (OFAC) announced on March 16, 2016 amendments to regulations restricting trade with Cuba in response to the President’s policy. These changes permit the following trade activities, previously restricted.   Travel to Cuba – (People to People Educational) by U.S. Persons to Cuba […]

DOD Distribution Statements

The Defense Department utilizes a series of Distribution Statements for technical data that describe the level of distribution authorized. These statements are labeled A-F and X.  Statement A is the least restrictive, signifying the data is approved for unlimited public distribution and Statement F the most restrictive which limits “further dissemination only as directed by […]

USML Category XII Proposed Revision

On February 19, the Commerce and State Departments published proposed revisions to USML Category XII and the EAR relating to the control of Fire Control, Lasers, Guidance and Control Equipment.   A previous version of the proposed rule was published on May 5, 2015; due to the comments received however, there was a complete re-draft for […]

Cuba Amendments

On January 27, 2016, new changes to the Cuban Assets Control Regulations (CACR) and the EAR went into effect, continuing the President’s policy of expanding relations with Cuba. Restrictions will be lifted on authorized exports and reexports, allowing U.S. banks to provide financing. This change will not apply for agricultural items and commodities. BIS has […]