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…
“Hey Alexa, are you a U.S. Person?” Imagine this. A conference call with your foreign-based customer is about to begin. Today’s agenda includes technical discussions of recent upgrades and changes to the designs of some ITAR-controlled items. Your Trade Compliance Officer has reviewed the material and confirmed that export authorizations are in place approving the…
This is the second post in a series of blogs about the proposed changes to USML Categories I, II and III. Please check back for further articles in this series. For more information about these changes, and the movement of items from ITAR to EAR, check out Part 1 in our series and read the…
This is the first in a series of blogs about the proposed changes to USML Categories I, II and III. Please check back for more updates soon. For more information about these changes, and the movement of items from ITAR to EAR, read our post on the latest firearms Export Control Reform updates. One…
If you’ve spent any time in trade compliance, you’ve probably come across the term “reasonable care.” But what, exactly, does that mean? The ambiguous nature of this phrase has caused many different interpretations over the years. Let’s review some practical ways to apply this principle to your global trade compliance program. The idea of “reasonable…
In recent weeks, we’ve seen significant activity from both the legislative and executive branches that could change the way foreign investment occurs in U.S. companies. These changes could also affect the export control compliance requirements of many companies who are targets of foreign investors. Keep reading for a brief history of CFIUS reviews, and the…
What Is ITAR and EAR Compliance? As a business operating in the defense industry, you know the complex regulations governing the export of military technology and sensitive information. Understanding and complying with ITAR (International Traffic in Arms Regulations) and EAR (Export Administration Regulations) is essential to avoid hefty fines, legal trouble, and reputational damage. In…
Routed Export Transactions And Your Business Have you ever struggled to determine the responsibilities and parties in a routed export transaction? If so, you’re not alone! Routed transactions make even the most experienced exporters pause. They have been described as dreaded, confusing, mysterious, and complicated! What is a Routed Export Transaction? The difference between a…
We get a lot of questions about exporting titanium products and other metals from the United States to a foreign country. It’s no simple process, and it’s easy to slip into a violation of U.S. export control regulations. Recently, I sat down with one of our clients – Performance Titanium Group (PTG) – to discuss…
Zhongxing Telecommunications Equipment Corporations, (“ZTE”), and its subsidiaries and affiliates entered into a settlement with three U.S. government agencies covering civil and criminal charges filed against the company. The proposed $1.9 billion settlement closes a five-year investigation into ZTE’s exporting and reexporting activities, whereby roughly $40 million of U.S.-origin goods passed through China to companies…