Category: Deemed Exports

Years ago, I heard an enforcement official describe deemed exports like “hugging a cloud.”  As soon as you had your arms around a situation, it would dissipate – evaporating into mist, expanding, visibly there, but at the same time, somehow, not there. Fast forward to today, and the same government agency is trying to get…

Deemed export laws are complicated.  They can be confusing for all people – even Elon Musk.  The serial entrepreneur and founder of SpaceX recently tweeted an (inaccurate) interpretation of U.S. export controls laws.  This stems from the Department of Justice suing SpaceX for alleged discriminatory hiring practices. Musk tweeted: US law requires at least a…

Do you think export control laws take precedence over employment laws?  Think again. Recently, two settlement agreements between the Department of Justice (DOJ) and U.S. companies highlight the complicated scenarios faced by many HR departments today.  Let’s take a closer look at General Motors and American CyberSystems Inc. More importantly, let’s find out what can…

Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go.  In recent years, these regulations continue to change and become more complex.  (Just count the pages in the Federal Register notices.  They keep piling up!)  Now more than ever, it’s crucial to understand…

“We don’t export anything.” This is something we hear all the time.  Sometimes, it’s followed by: “Well, we do ship stuff to Canada.  Does that count?”  (Pro Tip:  Yes, it counts.)  But other times, our clients really don’t put something in a box and send it to a foreign country.  Yet, they still need help….

Eighteen years before he wrote Jurassic Park, the novelist Michael Crichton penned a different story titled The Terminal Man.  It’s about a computer scientist who undergoes surgery to cure his seizures – having 40 different electrodes embedded in the amygdala part of his brain and connected to a small computer in his shoulder.  Spoiler alert! …

A few weeks ago, the U.S. Department of Justice (DOJ) issued a stark warning to companies and individuals worldwide.  Export and sanctions enforcement efforts are on the rise.  Especially for anyone who engages with China, Russia, North Korea or Iran. During a keynote address on October 5 in New York, associate deputy attorney general John…

James Bond makes it look so easy.  Zooming around in sports cars with an array of techno-gadgets at his fingertips, he outwits his adversaries and saves the world.  He does all of this while wearing tailor-made suits and sipping martinis.  After defeating every foe, he jets off to a villa in the French Riviera, where…

Deemed exports can present a challenging compliance environment for companies as they straddle export control regulations as well as employment and anti-discrimination law.  To understand the risks associated with deemed exports for an organization, it is recommended that the company understands the extent of their export-controlled items.  A deemed export is the release to a…

Unlicensed Exports Apply To All Foreign National Students It’s been several years since the imprisonment of John Reece Roth, a former University of Tennessee electrical engineering professor who was convicted of conspiracy, wire fraud and fifteen (15) violations of exporting ITAR controlled defense articles.  Professor Roth was involved in a U.S. Air Force contract for…