Earlier this week, I was updating our list of common ITAR exemptions and noticed that several have been added in recent weeks or months. As with most exemptions, these are narrowly defined and you, as the exporter, must be careful to meet all criteria outlined in the ITAR before proceeding. Some of the recent ITAR…
ITAR compliance is agreeably difficult, and exemptions are not “exempt” from this conundrum. Take, for example, the export of defense articles and technical data. When you export articles and technical data to support that article, they are considered completely separate items and require a separate authorization under the ITAR regulations. This rule is a bit…
Earlier this month, DDTC made final a new exemption for certain exports to the United Kingdom in §126.17 of the ITAR. This exemption is pursuant to the recent Defense Trade Cooperation Treaty between the United States and the United Kingdom. How much is this new exemption going to help your company’s ITAR compliance? And more…
Less than two months after they were added to the Excluded Party List System (EPLS), it now appears that the last of the freight forwarders have been removed from the EPLS – paving the way for a return to “business as usual” for exporters who were being restricted from certain trade activities involving these forwarders…
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…
Sanctions Imposed On ITAR Freight Forwarders Earlier this month, the Department of the Air Force imposed a sanction against six freight forwarding companies who allegedly engaged in anti-trust price-fixing. (UPDATE: That list has now been reduced to five.) As a result, these forwarders are debarred from engaging in government contracts. (And as a result of…
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…
We get a lot of questions from clients about what to do if they use suppliers who are not registered with DDTC to perform ITAR-related work. This presents an interesting dilemma. Although it’s clear that the supplier is violating Section 122.1 of the ITAR, is the company who sends that supplier ITAR-controlled work also violating…
Apparently, DDTC has encountered some glitches in its new process for online payment of ITAR registration fees. According to a recent notice on its website, DDTC states that a number of U.S. registrants have experienced difficulties transmitting ACH payments. Now the agency is offering an alternative method using FedWire. This brings the total number of…
The BIS recently published a list of seven new “best practices” to help companies improve their export trade compliance. Specifically, these best practices are designed to help avoid the diversion of dual-use items at international transshipment points (or “hubs”). Here are the seven best practices. It seems that this list comes up short on practical, real-world advice…