Category: EAR

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...

On February 24, 2020, the Bureau of Industry and Security (BIS) issued a Federal Register Notice revising the Country Group designations for Russia and Yemen based on national security, foreign policy, and proliferation-related concerns. BIS stated that this action was “intended to facilitate and support accountability in connection with exports and reexports of items” to...

The transition of Defense Articles from the ITAR (USML Categories I, II, and III) to the Export Administration Regulations (EAR) is here. The Final Rule published by Department of Commerce and the Final Rule published by Department of State will be effective on March 8, 2020. Are you ready? The regulatory language has been circulated...

Updated 1/23/2020 Choosing An ITAR Consultant For Your Business Let’s face it:  the world is rife with export “experts.”  One way to handle this is to ignore the problem and pretend that ITAR compliance doesn’t matter. If you want to take this approach, it’s certainly your choice. Another option is to ask questions that will...

Updated 1/09/2020 Navigating The Confusing Landscape Of Distribution Statements Have you ever been frustrated or stymied by those DoD Distribution Statements concerning Critical Technology, which appear to prohibit U.S. contractors from sharing the data with their partners in Canada? If so, you’re not alone! Well, there is a way to work within the framework of...

The New Year is here and with the new year comes increased penalties for export violations pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Act”) became law in November 2015. The stated purpose of the 2015 Act is...

The Export Solutions blog provides timely and helpful information to anyone who is responsible for import/export compliance.  If you haven’t subscribed yet, join our growing community by subscribing now to stay current on all that’s happening in the world of trade compliance. As we say goodbye to 2019, let’s take a look at our top...

Appropriate to the Season and to something that should stay with us all throughout the year... On the first day of Christmas my company gave to me- A Management Compliance Policy which establishes my management’s and my company’s commitment to export compliance; On the second day of Christmas my company gave to me- An Export...

It’s almost Thanksgiving and when I think Thanksgiving, I think about traditions. Truthfully, no one in my family even likes turkey and we’ve discussed deviating from eating it every year, but we just can’t do it! Why? Tradition! We have all kinds of traditions at this time of year: fighting over (ahem, I mean breaking)...