Category: ITAR

They say that change is inevitable and that the only thing constant is change. Most of us do not like change. We like our world to be the way that we are used to and comfortable in, but change is inevitable. The better you are prepared for change, the easier it is to accept and…

The Directorate of Defense Trade Controls (DDTC) has entered into a Consent Agreement with L3Harris Technologies, Inc. (“L3Harris”) for violations of the International Traffic in Arms Regulations (ITAR).  In its Proposed Charging Letter, DDTC alleged a total of one hundred thirty-one (131) violations.  The violations fall into the following categories: Unauthorized Exports of Technical Data…

We all get stuck in our ways sometimes. Some of us have had the same hair since 1980, others of us can’t let go of that old sweatshirt from high school. Some have trouble embracing the latest fashion trends. Those things can all be overlooked, but your Compliance Manual should always embrace the latest regulations….

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a…

Ever wonder why your license application is taking so long to be reviewed and approved? Many thoughts go through a Compliance Officer’s mind when the license process is taking longer than expected: “Did I make a mistake on the license application?” “Should I have provided more information?”  “Did I miss something in my due diligence?”…

After a delay due to the government shutdown, the U.S. government recently announced increases to civil penalties for export related violations. Pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, civil penalties for export related violations should have increased on 3 January 2019. However, given the fact that the USG was…

“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 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…