Category: Export Control Reform Initiative

Wanted: Your voluntary disclosures

Traditionally Export Related Voluntary Disclosures/Voluntary Self-Disclosures have been filed with DDTC, BIS, OFAC or occasionally the Bureau of Census. Each of these agencies encourages companies and individuals to file the Disclosures and they provide an incentive in that the filing can be considered as a mitigating factor to the violation(s) committed.

BIS allows new electronic submissions

Effective October 14, 2016, BIS has amended the Export Administration Regulations to allow for electronic submission of reporting requests U.S. persons receive to take action in furtherance or in support of an unsanctioned foreign boycott. Prior to this, reports were only permitted to be submitted by mail using BIS 621-P or BIS 6051-P.

Revisions to USML Category XII

The revision of USML Category XII was first published as a proposed rule on May 5, 2015, for public comment. The number of public comments received caused the Department of State to reevaluate the original proposed rule change and to draft a new proposed rule change (published February 19, 2016).