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…
This is the third installment in a series of articles called The Automation Dilemma, which highlights some of the common “do’s and don’ts” of automating your company’s export compliance process. Be sure to read Article #1 and Article #2, and keep checking back for future installments in this series. One of the problematic automation tasks…
This is the second installment in a series of articles called The Automation Dilemma, which highlights some of the common “do’s and don’ts” of automating your company’s export compliance process. Be sure to read Article #1 (Restricted Parties List Screening), and keep checking back for future installments in this series. One of the key elements…
Here’s a quick test. Select a random employee and ask him or her: “What does ITAR stand for?” Do they remember? Do they stutter while answering? Or do they just give you a funny look and walk away? Of course, your employees need to know much more than this simple question. (But hey, I told…
This is the first in a series of articles called The Automation Dilemma. During the next few weeks and months, we’ll discuss some of the common “do’s and don’ts” of automating your company’s export compliance process. Keep checking back for future installments in this series. In today’s world, many companies use different methods to automate…