Category: EAR

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…

This month, U.S. authorities imposed a $300 million civil penalty against Seagate Technology over its lucrative relationship with blacklisted Chinese technology firm Huawei Technologies.  The penalty was to resolve alleged violations of export controls related to selling hard disk drives.  The $300 million settlement announced by the Department of Commerce’s Bureau of Industry and Security (BIS) is…

Is it getting hot in here?  Or is it just summer approaching?  If you’re feeling a little “toasty,” we’re here to say that you aren’t imagining things.  The agency responsible for the Export Administration Regulations (EAR) just turned up the heat on exporters. Earlier this month, the Bureau of Industry and Security (BIS) released updated…

In the final scene of Back to the Future, Doc Brown prepares to take his time-travelling DeLorean into the future.  Marty warns Doc that they don’t have enough roadway to get the machine up to 88 mph for the time jump.  And then Brown famously says:  “Roads?  Where we’re going we don’t need roads.”  Cue…

In the Chinese zodiac, 2023 is the Year of the Rabbit.  The rabbit symbolizes many different attributes, including cautiousness and self-protection.  During a recent gathering of trade compliance professionals, I heard someone mention that 2023 is “the year of export enforcement.”  I must say that I agree.  These two types of “years” seem to fit…

“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….

It just got more expensive to violate U.S. import/export regulations. In recent weeks, the various governmental agencies who administer and enforce these regulations have released updated penalty amounts. The main culprit? Everyone’s favorite “I” word – inflation! Here’s a rundown of the new changes. Directorate of Defense Trade Control (DDTC) DDTC is the Department of…

When I started my career in trade compliance in 1990, our friends and foes were discussed in terms of “COCOM” – Coordinating Committee for Multilateral Export Controls.  COCOM was an established group of “western bloc” member states and cooperating countries whose mission was to enact an embargo on “eastern bloc” countries (mainly Russia).  During this…

As an American, born and raised in the United States of America, we tend to see our country as the world leader.  However, we know that the U.S. does not dictate to every other country but works well with others.  Just look at the many regimes we are a member of and actively participate in. …

Higher penalties. Suspended sentences. Admissions of fault. Public charging letters. Welcome to a new era of export enforcement. The Department of Commerce’s Bureau of Industry and Security (BIS) has changed the game when it comes to penalizing companies and individuals for export violations. How did they do it? And what does this mean for your…