Category: Best Practices

The Greek philosopher Heraclitus once famously said: “The only thing that is constant is change.” In the world of trade compliance, country sanctions and restricted parties lists are no exception to this rule. Time and time again, I see people with printed lists of countries posted near their computers, to remind them of where they…

HTS Chapter 98 And Your Business Savings and more savings on duties and fees are available for exporters who import their U.S. goods back into the United States. These savings are not BOGO (buy one, get one). Rather, they are for all U.S. goods returned (and some Non-U.S. goods). Have you ever reviewed Chapter 98…

In my last blog article, we examined the Specially Designed Decision Tool. Today, we will explore the new “Catch and Release” concept when determining if a product meets the definition of “Specially Designed.” First, here is the definition in the current ITAR. [My Notes will be in brackets, boldface, and Italics. All underlines are my…

This is the first in a series of articles called Tools of the Trade, where we will highlight some of the most useful tools and resources for export compliance professionals. Keep checking back for future installments! Classification of items (products, software, technology, etc.) is at the heart of any compliance program. Never has this been…

For all of you diligently screening your transactions against the many restricted parties lists published by the U.S. government, you are most likely aware that some items can actually be sent to some entities on the lists. The Unverified List, published by the Department of Commerce, Bureau of Industry and Security (BIS), was previously a…

If you haven’t already, it’s time to update your ITAR destination control statement on your commercial invoices. As part of the Export Control Reform that implemented on October 15, 2013, a new destination control statement should be used on your export paperwork. This change is effective immediately. The Destination Control Statement is required on the…

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…

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’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…

This is part of a series of blog articles titled The Automation Dilemma, which highlights some of the common “do’s and don’ts” when automating your company’s export compliance process. Be sure to read Article #1, Article #2, and Article #3 for all the posts in this series. Continuing with The Automation Dilemma series, I thought…