Traditionally Export Related Voluntary Disclosures/Voluntary Self-Disclosures have been filed with DDTC, BIS, OFAC or occasionally the Bureau of Census. Each of these agencies encourages companies and individuals to file the Disclosures and they provide an incentive in that the filing can be considered as a mitigating factor to the violation(s) committed. The number of agencies...
Moving one step closer to the Single IT system goal of Export Control Reform, DDTC has acquired a new case management IT system to modernize its business processes. Additionally, DDTC has begun accepting comments related to the new DS-7788 (Application for Permanent Export, Temporary Export or Temporary Import of Defense Munitions, Defense Services and Related...
In March of 1983, during a speech in Orlando, Florida, former President Ronald Reagan first used the phrase the “evil empire” to describe the Soviet Union. The phrase stuck, and a new era of emphasis on Export Regulations and Controls began. Stopping the USSR from acquiring U.S. technologies that could be used against us or...
The clock is ticking! Exporters have just one month (until November 15, 2016) to change the language and use of their Destination Control Statements (DCS). As the U.S. Government moves forward with the harmonization of export regulations under Export Control Reform, the ITAR and the EAR will soon be aligned with respect to the content...
The Export Administration Act has been in existence – in one form or another – for nearly 100 years. (Assuming you go all the way back to the Trading With The Enemy Act of 1917). In the late 1960’s, there was a reexamination of the U.S. Export Control system and a less restrictive Export Administration...
The U.S. Bureau of Industry and Security (“BIS”) recently issued administrative settlement documents against a company called Fulfill Your Packages ("FYP"). Under the settlement agreement, FYP agreed to pay a $250,000 fine, of which $190,000 was suspended on the condition that the company has no export violations over the next two years. According to the...
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...