There’s a lot of chatter among the export control community this week about the status of export license applications and other activities in light of the U.S. federal government shutdown. Some of the questions I’ve seen posted to discussion boards and blogs include: And my personal favorite … In some ways, I think it’s too…
I’ve talked with a lot of people over the years who are interested in hiring a consultant to help improve their company’s export compliance. Many of the questions asked during these discussions are the same – tactical questions about project scope, deliverables, timing, invoicing and more. Although it’s certainly important to discuss these issues, I…
A recent story in the Sarasota Herald-Tribune describes a raid conducted by law enforcement agents of a local warehouse owned by a multimillion-dollar package forwarding company named MyUS.com. The article provides few details on the raid, other than to say this is part of an active investigation related to “export enforcement.” It also quotes the…
This is the second installment in a series of articles called The Automation Dilemma, which highlights some of the common “do’s and don’ts” of automating your company’s export compliance process. Be sure to read Article #1 (Restricted Parties List Screening), and keep checking back for future installments in this series. One of the key elements…
Here’s a quick test. Select a random employee and ask him or her: “What does ITAR stand for?” Do they remember? Do they stutter while answering? Or do they just give you a funny look and walk away? Of course, your employees need to know much more than this simple question. (But hey, I told…
When it comes to EAR compliance, a common mistake is to find the Export Control Classification Number (ECCN) for your product and then make all your licensing determinations based on that alone. However, it’s important to remember there are actually two ECCNs for every item – one that controls the product, and a second that…
Ever heard of the BIS Entity List? More importantly, are you screening your transactions against this and other U.S. government watch lists? If you’re like most companies that we talk to, the answer to both of these questions is: “No.” In fact, it’s safe to say that many – and perhaps even most – companies…
The U.S. Bureau of Industry and Security (BIS) recently settled with Mattson Technology of Fremont, CA, in a case which alleges 47 EAR violations from 2006 to 2008. According to the order from BIS, Mattson “sold, transferred or otherwise serviced” pressure transducers “with knowledge that violations of the Regulations were about to occur or were…
An Australian man and his company have been charged with several counts of violating the EAR and ITAR (as well as OFAC trade embargoes). The charges point to an alleged scheme to export restricted items from the U.S. to Australia, for transshipment to Iran, in violation of numerous export control regulations. According to the Department…
Many clients are surprised when they start working on their export policy by the amount of flexibility there is – particularly when it comes to how they comply with the regulations. This most often occurs during the development or improvement of a company’s export compliance procedures. The basic goals of ITAR and EAR are relatively…