Is it just me, or does it seem like every day there is new activity through the Bureau of Industry and Security, Office of Export Enforcement (BIS-OEE)? OEE seems to be everywhere, fixated with ghoulish intensity on raising a graveyard of penalties. Let’s take a closer look at some examples and review the highlights from…
Halloween is the time of year for scary stories. Haunted houses, binging all the horror flicks, and exchanging ghost stories. For anyone working in trade compliance, some of the scariest stories don’t involve ghosts at all. They involve an export that left the building without the right authorization, a customer who turned out to be…
As export controls and sanctions have become more sophisticated, so have the strategies used to circumvent them. Products may be sold to a legitimate customer in one country, routed through another country, and then ultimately diverted to a restricted end user to a prohibited destination. This is known as diversion and is becoming a significant…
When you hear country names like North Korea, Russia and Syria, you may think bad juju. The United States has long standing opinions on these countries and their leaders, but Syria just received a major upgrade to how the United States views the country. On August 24, 2026, the Secretary of State rescinded Syria’s State…
Did you know that the anti-boycott laws are part of export compliance? If not, you are not alone, as this is often an overlooked due diligence requirement necessary to comply with the U.S. export laws. Understanding what U.S. anti-boycott compliance means and how it affects day-to-day operations is key to adhering to the requirements. These…
Last week, I wrote about the Bureau of Industry and Security’s (BIS) Streamlining Export Controls for Drone Exports Interim Final Rule and why businesses shouldn’t let complicated Federal Register language scare them away from potentially valuable export opportunities. Well…things just got more interesting. BIS has now issued its final rule, and there are some important…
Have you ever read a Federal Register notice and immediately felt overwhelmed by terms like “Interim Final Rule” (IFR), “License Exception STA”, or “Country Group A:1”? You’re not alone. Many businesses stop reading at the legal jargon, which means they often miss opportunities that could make exporting easier and more competitive. One recent example is…
What Changed? Well, well, well…UAE, the country that exporters for years have been warned about for diversion risks, was just upgraded to Country Group A:5 and completely removed from Country Group D, specifically D:3 and D:4. (Note that Supplement 1 to Part 740 is yet to be updated, but the press release is on the…
When a Shipment Becomes a Crisis and How Export Violations Can Cripple a Company What do General Electric Company, Precision Castparts, RTX, and 3D Systems Corporation all have in common? If you said they all have a public settlement for allegations of violating ITAR regulations, you’re right! In global trade, there’s always pressure to move…
We all know that having an EAR99 export classification is quite favorable for exporters. Typically, it allows for No License Required (NLR) exports if other considerations and requirements such as end use and restricted party screening have been met. However, let’s look at a common scenario that may not be on your radar outside of…