Recent stories here and here (and just about everywhere else) are pointing to an ongoing investigation, recently trumpeted by two Congressmen, which claims that NASA may have been involved in illegal exports of sensitive technologies to China. The basic allegations of the investigation are that individuals from NASA’s AMES Research Center conducted illegal transfers of…
A recent story in the Sarasota Herald-Tribune describes a raid conducted by law enforcement agents of a local warehouse owned by a multimillion-dollar package forwarding company named MyUS.com. The article provides few details on the raid, other than to say this is part of an active investigation related to “export enforcement.” It also quotes the…
This is the second installment in a series of articles called The Automation Dilemma, which highlights some of the common “do’s and don’ts” of automating your company’s export compliance process. Be sure to read Article #1 (Restricted Parties List Screening), and keep checking back for future installments in this series. One of the key elements…
Here’s a quick test. Select a random employee and ask him or her: “What does ITAR stand for?” Do they remember? Do they stutter while answering? Or do they just give you a funny look and walk away? Of course, your employees need to know much more than this simple question. (But hey, I told…
Joseph Debose, 30, – a resident of North Carolina and former Staff Sergeant with a U.S. Special Forces National Guard Unit – faces up to 20 years imprisonment for the illegal export of firearms to China. The government has charged Debose with making multiple shipments of semiautomatic handguns, rifles and shotguns to customers in China….
What is considered ITAR? Historically, the answer to that question has been very far-reaching and intentionally broad – encompassing a wide array of end items, sub-assemblies, components, materials and services. However, a recent proposed rule by the DDTC (and a concurrent rule from BIS), is proposing to change all that. If made final, this new…
Yesterday it was announced that United Technologies (UTC) and two of its subsidiaries – Pratt & Whitney Canada and Hamilton Sundstrand – have entered into a consent agreement with the U.S. Department of State. The companies will pay $75 million in ITAR violation penalties, to settle a total of 576 separate charges alleging wrongdoing. According…
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…