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…
In July 2016, the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) announced that it had re-initiated its Company Visit Program for companies engaged in ITAR-controlled work. The stated objectives of this program are: Advance DDTC’s understanding of how different companies establish and maintain an overall defense trade control program to fit the…
Moving one step closer to the Single IT system goal of Export Control Reform, DDTC has acquired a new case management IT system to modernize its business processes. Additionally, DDTC has begun accepting comments related to the new DS-7788 (Application for Permanent Export, Temporary Export or Temporary Import of Defense Munitions, Defense Services and Related…
The clock is ticking! Exporters have just one month (until November 15, 2016) to change the language and use of their Destination Control Statements (DCS). As the U.S. Government moves forward with the harmonization of export regulations under Export Control Reform, the ITAR and the EAR will soon be aligned with respect to the content…
Here’s a question we see all the time: We’re registered as a manufacturer of defense articles, but we do not export. So, why do we need a compliance program with written policies and procedures? To answer this question, let me provide a real-world illustration from a recent Government Accounting Office (GAO) document. A special “heads-up”…
For any industry, the “cost of doing business” inevitably increases over time. For companies engaged in ITAR-controlled work, the cost of not doing business compliantly is about to skyrocket. DDTC has announced that, effective August 1, 2016, the maximum amount that can be levied as a Civil Monetary Penalty will change. Most notably, for each…
Here’s one for all the Human Resources professionals out there. The U.S. Department of Justice Office of Special Counsel for Immigration-Related Unfair Employment Practices (the “OSC”) has issued a response to a request for guidance regarding complying with antidiscrimination laws (specifically under the Immigration and Nationality Act, or “INA”) when verifying employees’ citizenship status under…
How do you build a “culture of trade compliance” in your organization? You might as well ask, “How do you eat an elephant?” In both cases, the answer is seemingly simple, yet also complex – one bite at a time. A quick search for “culture of compliance” on the internet yields thousands of scholarly and…
Chinese national Fuyi “Frank” Sun has been arrested in connection with a plot to illegally export high-grade carbon fiber from the United States to China. Sun was arrested while traveling to New York to close a deal with a distributor of the fiber which is typically used for aerospace and military purposes. Turns out the…