For those of you in the crude oil exporting business, life has just gotten a little bit easier. The CCL entry (ECCN 1C981) requiring a BIS license to export crude oil out of the United States has now been removed and the new classification will be EAR99. Last month, a rule was issued by BIS...
Regular readers of this blog will know that, effective July 1, 2014, DDTC completed the revision of four USML categories. With these revisions, a variety of ITAR-controlled items were transitioned to the control of the EAR. As a reminder, these revised categories were: DDTC and BIS allowed for a period of time for the transition...
Here’s one for all the Human Resources professionals out there. The U.S. Department of Justice Office of Special Counsel for Immigration-Related Unfair Employment Practices (the “OSC”) has issued a response to a request for guidance regarding complying with antidiscrimination laws (specifically under the Immigration and Nationality Act, or “INA”) when verifying employees’ citizenship status under...
How do you build a “culture of trade compliance” in your organization? You might as well ask, “How do you eat an elephant?” In both cases, the answer is seemingly simple, yet also complex – one bite at a time. A quick search for “culture of compliance” on the internet yields thousands of scholarly and...
Chinese national Fuyi “Frank” Sun has been arrested in connection with a plot to illegally export high-grade carbon fiber from the United States to China. Sun was arrested while traveling to New York to close a deal with a distributor of the fiber which is typically used for aerospace and military purposes. Turns out the...
A Singapore man, Lim Yong Nam (aka Steven Lim) was extradited to the U.S. from Indonesia (where he’d been detained since October 2014) to face charges stemming from his alleged role in a conspiracy to illegally export radio frequency modules to Iran. According to the U.S. Government, some of these modules ended up being used...
Buried in the depths of the Federal Register notices published by DDTC, BIS and OFAC is an often-overlooked section that contains some very interesting predictions. This is the section to fulfill the Office of Management and Budget (OMB) requirement that government agencies communicate things like impact statements, time required to complete new forms and other...
DDTC recently published proposed amendments to USML Categories VIII and XIX. These amendments follow a period of public comment that began last year. The amendments are open to further public comment from now until March 25, although it’s doubtful there will be any significant further changes. After this, we expect DDTC to publish Final Rule...
One of the lesser-understood rules in the Export Administration Regulations (EAR), is the de minimis rule, which determines whether foreign-made products that incorporate U.S.-controlled content are subject to the EAR. While making international trade easier and better defining the jurisdiction and classification of items, the Export Control Reform (ECR) Initiative has also complicated the application...
Earlier this month, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) denied export privileges for two individuals and three companies. The actions center around a conspiracy to illegally export web-monitoring and controlling equipment and software to Syria. In particular, this conspiracy involved the Syrian Telecommunications Establishment (STE). “The settlement announced today results...