Category: ITAR

“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 third 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 and Part 2 in our series...

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...

Like many trade compliance professionals, I go out and peruse various trade compliance newsletters, the U.S. government agencies websites, and other media to keep up-to-date on compliance issues.  Recently, my attention was caught by a case involving Darling Industries of Tucson, Arizona. A closer look at Empowered Officials On February 28, 2019, the Directorate of...

On May 24, 2018, the Departments of State and Commerce published proposed revisions to U.S. Munitions List (USML) Categories I, II, and III in the Federal Register. These three categories would be the last USML categories to be revised under the Export Control Reform Initiative – a process that began more than nine years ago...

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 addition to federal workers impacted by the current government shutdown, companies who rely on the federal government to support their import/export compliance are also feeling the impact. We thought it might be helpful to provide the status of the various government agencies involved with assisting importers and exporters during this shutdown. Please Note: This...

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...

Last week, FLIR Systems, Inc. entered into a Consent Agreement with Department of State, Directorate of Defense Trade Controls (“DDTC”) to settle allegations of violations of the International Traffic in Arms Regulations (“ITAR”). There were 347 alleged violations cited in the Proposed Charging Letter. These violations included 219 counts of unauthorized exports to Foreign-Person employees;...