Category: Best Practices

What Does OFAC Compliance Mean For Your Business? We frequently talk about BIS and DDTC when it comes to export compliance, but less often, do we discuss the importance of OFAC compliance. When it comes to OFAC compliance, there are three mistakes we often see companies make: Failing to Understand How Far-Reaching the OFAC Sanctions…

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).  Moi?  Yes, you.  Don’t panic, there’s plenty of time to get certified, but you really need to get rolling now. Between June and September of…

Updated 1/24/2020 Understanding The Role Of An Exporter Or Record 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.” Although Freight Forwarders…

Updated 1/23/2020 Is Your Company’s Understanding Of ITAR Procedures Flawed? Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine): Export-controlled technical data has a unique set of rules designed to ensure that it is not inadvertently released or “exported” to…

Updated 1/18/2020 Asking The Right Question: Are You Trade Compliant? Very often, we talk with individuals who are focused on specific needs. They have questions like: “How do I get an ITAR license?” or “What is the ECCN for my product?” Although these questions are valid and important, sometimes companies need to take a step…

Updated 1/14/2019 The ITAR Exemption Handbook Intro Many people focus on the need to obtain an ITAR license, without first considering whether or not an exemption may apply to their transaction. What is an ITAR exemption? Simply put, an exemption is a set of conditions which – if met – allow you to ship to…

The holidays are here, and many of us take this time of year to reflect on all that we have to be thankful for.  If your company is registered pursuant to §122.1 of the International Traffic in Arms Regulations (ITAR), you may well be thankful that the new DECCS Registration Form and Process haven’t been…

Appropriate to the Season and to something that should stay with us all throughout the year… On the first day of Christmas my company gave to me- A Management Compliance Policy which establishes my management’s and my company’s commitment to export compliance; On the second day of Christmas my company gave to me- An Export…

They say that change is inevitable and that the only thing constant is change. Most of us do not like change. We like our world to be the way that we are used to and comfortable in, but change is inevitable. The better you are prepared for change, the easier it is to accept and…

The Directorate of Defense Trade Controls (DDTC) has entered into a Consent Agreement with L3Harris Technologies, Inc. (“L3Harris”) for violations of the International Traffic in Arms Regulations (ITAR).  In its Proposed Charging Letter, DDTC alleged a total of one hundred thirty-one (131) violations.  The violations fall into the following categories: Unauthorized Exports of Technical Data…