On December 26, 2019, DDTC issued an Interim Final Ruling which outlined changes to the ITAR and significantly, to ITAR Encryption Rules. Now that the Final Rule is in place and the changes are implemented, it is time to be more specific.
With the COVID-19 pandemic, some companies will become prime targets for acquisitions, mergers and investments. Others may recognize that their survival is in being acquired or merged with existing companies, or in receiving investments to continue. Perhaps it is time to revisit what this means for companies.
We were honored to be interviewed for a recent story by The Wall Street Journal about the growing complexity of U.S. sanctions and trade compliance regulations.
The Department of Justice released a superseding indictment in its federal case against Huawei Technologies Co., Ltd. The superseding indictment consolidated and expanded upon earlier charges of bank and wire fraud, sanctions violations, trade secret theft, and obstruction issues against Huawei and its subsidiaries.
Are you conducting business with the Department of Defense? If your answer is “yes,” you’ll soon need to comply with the new standards based on the Cybersecurity Maturity Model Certification (CMMC). Don't panic, there’s plenty of time to get certified, but you really need to get rolling now.
On February 24th, BIS issued a Federal Register Notice revising the Country Group designations for Russia and Yemen based on national security, foreign policy, and proliferation-related concerns. BIS stated that this action was “intended to facilitate and support accountability in connection with exports and reexports of items” to Russia and Yemen.
On January 29,2020, Airbus SE of the Netherlands became another cog in the wheel of export enforcement. Airbus agreed to a settlement with DDTC of $10 million covering 75 violations of the Arms Export Control Act (AECA) and Part 130 of the ITAR for the time period 2011 through 2019.
The transition of Defense Articles from the ITAR (USML Categories I, II, and III) to the Export Administration Regulations (EAR) is here. Are you ready? The regulatory language has been circulated for comment, revised and re-revised for years, but now it’s final.
Despite the glib title of this blog article, we have been noticing a trend in companies using Freight Forwarders directed by their foreign customers. The goal, in many cases, seems to be for the seller to avoid being the “Exporter of Record.”
Let’s face it: the world is rife with export “experts.” One way to handle this is to ignore the problem, and pretend that ITAR compliance doesn’t matter. If you want to take this approach, it’s certainly your choice.Another option is to ask questions that will help separate the wheat from the chaff. These 10 questions come from my personal playbook. They’ll help filter out all but the best con artists, and they’ll also identify those consultants who think they know export compliance because their former employers sent them to a seminar last year.