Category: Best Practices

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…

We all get stuck in our ways sometimes. Some of us have had the same hair since 1980, others of us can’t let go of that old sweatshirt from high school. Some have trouble embracing the latest fashion trends. Those things can all be overlooked, but your Compliance Manual should always embrace the latest regulations….

In a previous blog, we discussed the concept of “reasonable care” as it applies to your trade compliance program.  The focus was how export and import programs dovetail with many other areas of compliance, such as policies and procedures, valuation, Free Trade Agreements, and more.  Today, I’d like to switch gears and talk about how…

Within a few short weeks, the International Chamber of Commerce (“ICC”) will release the much-anticipated INCOTERMS 2020 and, as it did in 2010, the publication of the ICC decisions will change the landscape of international trade.  As you may remember, the INCOTERMS were reduced from thirteen (13) to eleven (11) with the 2010 revisions. While…

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a…