Category: Best Practices

This month, DDTC has introduced new versions of several different forms for exporters to use with their ITAR licenses and registrations. It’s important to use these new versions of the documents, because DDTC will no longer be accepting the previous versions. Here’s a brief summary of the new documents: It’s important to make note of...

The State Department is following Commerce’s lead with reaching out to industry on the export control reform tools. As part of the Directorate of Defense Trade Controls (DDTC) outreach efforts for the initial implementation of Export Control Reform final rule published on April 16, 2013, DDTC has developed a new web-based decision tool that will...

To comply with a federal mandate, DDTC will be upgrading its DTrade system for electronic license applications over the next few months. The new upgrades will ensure compliance with Access Certificates for Electronic Services (ACES) SHA-256 (“SHA-256”) digital certificates. This means that all DTrade users must purchase and register a new SHA-256 certificate by the...

If there’s a silver lining in every cloud, then the recent ITAR penalties levied against Aeroflex, Inc. and its subsidiaries can hold some valuable lessons for other companies. On July 25, DDTC charged the microelectronics manufacturer with 158 violations of the AECA and ITAR. The alleged violations cover an extensive time period – more than...

I hear it from every client: “We want to be complaint, but we need a simple system and a process that will actually work.” That, to me, is the name of the game. In my years at GE Aviation, there were many great ideas, new programs and processes to follow. But the most effective ones...

Earlier this month, the U.S. Department of Energy (DoE) published a proposed new rule that would make formal its expectations for contractors to comply with export control laws and regulations. The new rule also establishes some mandatory export control requirements for DoE contractors (explained below). In my mind, this proposed rule is a signal of...

I’ve talked with a lot of people over the years who are interested in hiring a consultant to help improve their company’s export compliance. Many of the questions asked during these discussions are the same – tactical questions about project scope, deliverables, timing, invoicing and more. Although it’s certainly important to discuss these issues, I...

Here’s a recent enforcement case that underscores the importance of a robust restricted parties screening approach as part of your company’s export compliance policies. Last month, Alex Tsai and Gary Tsai – father and son, both from Taiwan – were arrested for allegedly attempting to export to North Korea a variety of machines which can...

The U.S. Bureau of Industry and Security (BIS) has launched two new, online tools to help manufacturers and exporters begin to apply some of the recent changes under the export control reform initiative. These tools can be useful as your company prepares for the final rules to take effect this October. Each tool utilizes a...

The Department of Treasury, Office of Foreign Assets Control (OFAC) has released a new Specially Designated Nationals screening tool for the public to use. One of the improvements is that this new tool employs “fuzzy logic.” In simple terms, that means the tool will screen for other possibilities that are not a true, 100% match....