In addition to federal workers impacted by the current government shutdown, companies who rely on the federal government to support their import/export compliance are also feeling the impact. We thought it might be helpful to provide the status of the various government agencies involved with assisting importers and exporters during this shutdown.
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.
Last week, FLIR Systems, Inc. entered into a Consent Agreement with Department of State, Directorate of Defense Trade Controls (“DDTC”) to settle 347 alleged violations of the ITAR. Keep reading for more details on what went wrong.
We field lots of questions about the difference between ITAR and EAR regulations, particularly with the changes from Export Control Reform in recent years. How can you distinguish ITAR vs. EAR?
Earlier this month, DDTC published a new Consent Agreement with Bright Lights USA, Inc. of Barrington, New Jersey. This agreement alleges a variety of different ITAR violations, including technical data exports and failure to keep adequate records.
Yu Long, a Chinese citizen and former employee of the United Technologies Research Center (UTRC) pleaded guilty to the export and the attempted export of defense articles from the U.S. in violation of the Arms Export Control Act. The maximum possible sentence Long can serve is 20 years.
On 20 December 2016, in the Federal District of Connecticut, JIANG YAN, 34, of Shenzhen China was sentenced to time served (12 months imprisonment) for attempting to purchase and export to China without a required export authorization for certain sophisticated integrated circuits used in military satellites and missiles. Additionally, for conspiring to sell counterfeits of those same integrated circuits to a purchaser in the United States. Yan was also ordered to forfeit $63,000 in cash seized incident to his arrest.
While you are trying to figure out where you left off before Christmas, keep in mind that a new Harmonized Tariff Schedule is now in effect for 2017. The new HTS is available online.
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.