Lately, everyone is focused on changes to U.S. export control regulations and related trade initiatives. And while the landscape is changing here in the United States, let’s not forget about China’s proposed new Export Control Law (“ECL”) which, although still in draft form, has passed the stage of public comments.
Category: Export Control Reform Initiative
In recent weeks, we’ve seen significant activity from both the legislative and executive branches that could change the way foreign investment occurs in U.S. companies. Keep reading for a brief history of CFIUS reviews, and the proposed new legislation – FIRRMA.
DDTC has released its first summary report from the re-initiated Company Visit Program. Is your company following these best practices and recommendations?
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.
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.
Moving one step closer to the Single IT system goal of Export Control Reform, DDTC has acquired a new case management IT system to modernize its business processes. Additionally, DDTC has begun accepting comments related to the new DS-7788.
The clock is ticking! Exporters have just one month (until November 15, 2016) to change the language and use of their Destination Control Statements (DCS).
Regular readers of this blog will know that, effective July 1, 2014, DDTC completed the revision of four USML categories. The transition deadline for licenses under these revised categories is quickly approaching.
Buried in the depths of the Federal Register notices published by DDTC, BIS and OFAC is an often-overlooked section that contains some very interesting predictions.
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).