Recently, a South Carolina company, STREIT USA, was fined $3.5 million to settle charges related to the sale of U.S.-origin vehicles to end-users located in multiple countries. The company is part of STREIT Group, which is a global manufacturer of armored vehicles for military, security, luxury and other markets. As part of the settlement, $1.5…
Stop me if you’ve heard this one. Your Business Development Manager (we’ll call him “Bob”) is at a military trade show somewhere in the Middle East. A guy from that region exchanges business cards with Bob, chats for a few minutes, then splits. A few weeks later, Bob receives an email from the gentleman, asking…
Last week, oil and gas giant Schlumberger plead guilty to facilitating trade with Iran and Sudan, in violation of U.S. sanctions. The parent company’s Schlumberger Oilfield Holdings Ltd. (SOHL), which is a wholly-owned subsidiary of Schlumberger Ltd., agreed to a guilty plea for conspiring to violate the International Emergency Economic Powers Act (IEEPA) by willfully…
In my last blog article, we examined the Specially Designed Decision Tool. Today, we will explore the new “Catch and Release” concept when determining if a product meets the definition of “Specially Designed.” First, here is the definition in the current ITAR. [My Notes will be in brackets, boldface, and Italics. All underlines are my…
This is the first in a series of articles called Tools of the Trade, where we will highlight some of the most useful tools and resources for export compliance professionals. Keep checking back for future installments! Classification of items (products, software, technology, etc.) is at the heart of any compliance program. Never has this been…
For all of you diligently screening your transactions against the many restricted parties lists published by the U.S. government, you are most likely aware that some items can actually be sent to some entities on the lists. The Unverified List, published by the Department of Commerce, Bureau of Industry and Security (BIS), was previously a…
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…