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…
We hear a lot of misconceptions about ITAR and EAR in the process of educating people on these complex regulations. Here are five of the most common misconceptions people make during our various import export training sessions. 1. “Is this ITAR, EAR or both?” Any given product, information or technology could be controlled by either ITAR or EAR, but it…
DDTC’s proposed new rule on dual and third-country nationals (DN/TCN) becomes final August 15, 2011. We previously blogged about that new rule here, in case you missed it. In preparation for the implementation of these provisions, DDTC has published a variety of guidelines and answers to frequently asked questions about the new 126.18 exemption. Thankfully, these documents provide more…
Ever heard of The Parts Guys? Neither had I. Now, it seems, the whole world knows about this business and its president, Michael Edward Todd. The Parts Guys, LLC, is a company in Port Orange, Florida, which also operates a warehouse in Macon, Georgia. (I’m going out on a limb and guessing these guys sell…
The DDTC Rolling Out New Rules & Regulations DDTC has served up a new proposed exemption for ITAR replacement parts and incorporated components. This follows several DTAG recommendations, some of which have been incorporated into the new language, and others which have not. Here’s a look at the new proposed exemption as it currently stands: We’ll have…