License Exception ‘CIV’ (Civil End-Users §740.5) is soon to be eliminated. CIV authorized exports and reexports of items on the Commerce Control List (CCL) which had a license requirement to the ultimate destinations pursuant to the Commerce Control Country Chart for National Security (“NS”) reasons only; and identified by ‘CIV: Yes’ in the License Exception…
This past week, the Trump administration announced a ban on exports of certain types of Personal Protective Equipment (PPE) in response to the COVID-19 crisis. The new rule became effective immediately and will last four months (until August 8, 2020). While this type of activity is unusual due to its breadth and scope, those of…
The New Face Of ITAR Compliance For Your Business 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…
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…
How Your Business Benefits From ITAR Consultants Navigating the complexities of International Traffic in Arms Regulations (ITAR) is crucial for companies involved in trade compliance. With stringent requirements from the Department of State, including detailed policies, licensing, training, and auditing, the role of an ITAR consultant becomes invaluable. These experts understand the specific needs of…
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…