Category: Best Practices

Many clients are surprised when they start working on their export policy by the amount of flexibility there is – particularly when it comes to how they comply with the regulations. This most often occurs during the development or improvement of a company’s export compliance procedures. The basic goals of ITAR and EAR are relatively...

We get a lot of questions from clients about what to do if they use suppliers who are not registered with DDTC to perform ITAR-related work. This presents an interesting dilemma. Although it’s clear that the supplier is violating Section 122.1 of the ITAR, is the company who sends that supplier ITAR-controlled work also violating...

Recently, I’ve been involved in a lot of ITAR compliance training sessions for employees. If your company spends time and resources to develop an effective compliance program, but you fail to train your employees in the management of that program, then all of your hard work will go to waste. Here are four tips I...

I worked for GE Aviation for 25 years, and had many dealings with GE’s unions during that time. Needless to say, the relationship between those unions and GE management was lukewarm – at best. It’s no surprise that there was often mutual distrust on both sides. One of the results of this was often a...

Many trade compliance departments are faced with the decision to assign both a Schedule B Number and a Harmonized Tariff Schedule (HTS) code to their products, or just to assign the HTS code only. Since many companies are importing and exporting today, international corporations must fulfill the requirements for both import and export clearances. U.S....

As if the recent upgrades to the registration process weren’t enough, DDTC has truly outdone themselves today. There’s a new section on their website which posts final determinations from the Commodity Jurisdiction (CJ) Requests they receive. You can access it here. (Hurry! Click the link now, before we all wake up and realize this is...

The BIS recently published a list of seven new “best practices” to help companies improve their export trade compliance.  Specifically, these best practices are designed to help avoid the diversion of dual-use items at international transshipment points (or “hubs”). Here are the seven best practices. It seems that this list comes up short on practical, real-world advice...

It’s easy to focus on ITAR, EAR and OFAC ... and forget about some of the other U.S. Government acronyms that have an impact on exporters. Today, we’ll take a closer look at the Foreign Trade Regulations (FTR). The FTR is administered by the U.S. Census Bureau. (The reason for Census involvement is because FTR...

The U.S. Bureau of Industry and Security (BIS) recently released a new guide to help U.S. companies comply with the Export Administration Regulations (EAR).  This 145-page document, which is available for free here, contains a number of helpful insights, sample tools and recommendations for “How to Develop an Effective Export Management and Compliance Program.” BIS tackles the subject...