Category: Best Practices

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). As the U.S. Government moves forward with the harmonization of export regulations under Export Control Reform, the ITAR and the EAR will soon be aligned with respect to the content...

Here’s a question we see all the time: We’re registered as a manufacturer of defense articles, but we do not export. So, why do we need a compliance program with written policies and procedures? To answer this question, let me provide a real-world illustration from a recent Government Accounting Office (GAO) document. A special “heads-up”...

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 foreign persons either inside or outside the United States. As...

Here’s one for all the Human Resources professionals out there. The U.S. Department of Justice Office of Special Counsel for Immigration-Related Unfair Employment Practices (the “OSC”) has issued a response to a request for guidance regarding complying with antidiscrimination laws (specifically under the Immigration and Nationality Act, or “INA”) when verifying employees’ citizenship status under...

How do you build a “culture of trade compliance” in your organization? You might as well ask, “How do you eat an elephant?” In both cases, the answer is seemingly simple, yet also complex – one bite at a time. A quick search for “culture of compliance” on the internet yields thousands of scholarly and...

Let’s assume that you’re traveling internationally with your ITAR-controlled product and you have a valid DSP-73 license in place. (If I’ve already lost you with that sentence, then please skip the rest of this article and schedule a no-charge consultation with us today.) Rather than shipping the item to your destination, it makes more sense...

The 2016 editions of the Harmonized Tariff Schedule (HTS) and the Schedule B have now been issued and the Automated Export System (AES) has been updated with the new codes. While the changes are relatively few, some exporters and importers may find that their classifications are now invalid. Don’t fret, though. You have a 30-day...

Beginning Thursday, November 26, 2015 (Thanksgiving Day), DTrade users must use new versions of all license application forms, as well as the DS-2032 registration form. These forms are to comply with an updated version of DTrade. The new forms cover all DDTC license applications, including: The new forms also include: Earlier versions of these forms...

One of the lesser-understood rules in the Export Administration Regulations (EAR), is the de minimis rule, which determines whether foreign-made products that incorporate U.S.-controlled content are subject to the EAR. While making international trade easier and better defining the jurisdiction and classification of items, the Export Control Reform (ECR) Initiative has also complicated the application...

Looking for someone to conduct a gap analysis of your trade compliance activities? Consultants come in all shapes and sizes, with various backgrounds, skills and expertise. But not all consultants (or their assessments) are created equal! Before you give that consultant a green light, make sure you have a thorough understanding of what they'll be...