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…
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 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;…
What Is ITAR and EAR Compliance? As a business operating in the defense industry, you know the complex regulations governing the export of military technology and sensitive information. Understanding and complying with ITAR (International Traffic in Arms Regulations) and EAR (Export Administration Regulations) is essential to avoid hefty fines, legal trouble, and reputational damage. In…
Earlier this month, DDTC published a new Consent Agreement with Bright Lights USA, Inc. of Barrington, New Jersey. This agreement alleges a variety of different ITAR violations, including technical data exports and failure to keep adequate records. Are these problems sufficiently addressed in your company’s export compliance program? As always, it’s important to take note,…
On 20 December 2016, in the Federal District of Connecticut, JIANG YAN, 34, of Shenzhen China was sentenced to time served (12 months imprisonment) for attempting to purchase and export to China without a required export authorization for certain sophisticated integrated circuits used in military satellites and missiles. Additionally, for conspiring to sell counterfeits of…
Yu Long, a Chinese citizen and former employee of the United Technologies Research Center (UTRC) pleaded guilty to the export and the attempted export of defense articles from the U.S. in violation of the Arms Export Control Act. The maximum possible sentence Long can serve is 20 years. Long, who was a legal resident in…