Category: EAR

As trade compliance professionals, many of us are just trying to keep our head above water with the changing compliance scene. There is no longer a status quo within the regulations as the compliance boundaries are shifting on a daily basis. Such is the case with the announcement on June 15, 2020 from the Department…

In response to a Final Rule published by the Bureau of Industry and Security (BIS) and effective in March 2020 moving certain firearms, guns, and ammunition to the Commerce Control List (CCL), the Automated Export System (AES) has been updated to create a new license type, C63, for items not having the same controls as…

Business Has Changed, It’s Time For Trade Compliance To Change, Too As the business world adapts to face masks, Zoom calls and social distancing, the trade compliance community is also re-evaluating the way it does business. While a lot has changed in your business, one thing that is certain to change – and, in fact,…

No one wants to really talk about trade compliance or acknowledge if it is lacking or non-existent. Not only is trade compliance an overwhelming and complicated mix of regulations, it is also something that puts most people to sleep! Often times employees think someone else is handling import compliance, but nobody is fully dedicated to…

During tough economic times with layoffs, downsizing and budget cuts, companies look for ways to save money and deliver results more efficiently. Like other aspects of your business, you might be in a position where you need to find ways to cut costs while maintaining a high level of standards for your import and export…

The end of April saw a double whammy of belt-tightening for many exporters as the Bureau of Industry and Security (BIS) imposed additional restrictions on the exports, reexports or transfers of specific goods, equipment materials or software to China, Russia, and Venezuela. Changes Continue to Occur Last week, we reported on the changes being addressed…

License Exception ‘CIV’ (Civil End-Users §740.5) is soon to be eliminated. CIV authorized exports and reexports of items on the Commerce Control List (CCL) which had a license requirement to the ultimate destinations pursuant to the Commerce Control Country Chart for National Security (“NS”) reasons only; and identified by ‘CIV: Yes’ in the License Exception…

This past week, the Trump administration announced a ban on exports of certain types of Personal Protective Equipment (PPE) in response to the COVID-19 crisis.  The new rule became effective immediately and will last four months (until August 8, 2020). While this type of activity is unusual due to its breadth and scope, those of…

On December 26, 2019, DDTC issued an Interim Final Ruling which outlined changes to the ITAR and significantly, to ITAR Encryption Rules. My Blog, “When is an Export not an Export” (published on 12/30/2019), discussed in general terms the Interim Final Ruling  and the changes that would become effective on March 25, 2020. Now that the Final Rule is in place…

Benjamin Franklin once stated that “Out of Adversity Comes Opportunity.” COVID-19 is the adversity- a tremendous difficulty. Companies forced to close their doors, employees laid off, lockdowns and stay-at-home orders could not be more adverse or difficult to our way of life; yet it is an unfortunate reality. Opportunities in Adversity So where are the…