Category: EAR

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…

Updated 1/23/2020 Does Your Business Need An ITAR Consultant? International trade is an essential part for many businesses, and your company is required to comply with various export administration regulations. One of the countless regulations, laws, and controls administered by the United States is the International Traffic In Arms Regulations (ITAR). Numerous U.S. agencies oversee…

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? Distribution Statements are technical documents If so, you’re not alone! While Distribution Statements seem overwhelming, at…

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)…

Export classification can be tricky enough on its own, but add in encryption and you have a whole different ball game. I like to equate encryption to baseball, because putting something into an analogy helps me understand it better. An entire game of baseball from beginning to end can be really hard to sit through…

On August 30th, BIS published Due Diligence Guidance regarding exports, re-exports, and transfers to Pakistan. With the increased concern regarding Pakistan’s nuclear program and risks of diversion, BIS is urging companies to conduct additional due diligence when it comes to transactions destined for Pakistan. The guidance highlights supplemental licensing requirements, as well as best practices…

We all get stuck in our ways sometimes. Some of us have had the same hair since 1980, others of us can’t let go of that old sweatshirt from high school. Some have trouble embracing the latest fashion trends. Those things can all be overlooked, but your Compliance Manual should always embrace the latest regulations….

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a…

After a delay due to the government shutdown, the U.S. government recently announced increases to civil penalties for export related violations. Pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, civil penalties for export related violations should have increased on 3 January 2019. However, given the fact that the USG was…