Category: Other Import/Export

On December 26, 2019, DDTC issued an Interim Final Ruling which outlined changes to the ITAR and significantly, to ITAR Encryption Rules. My Blog, “When is an Export not an Export” (published on 12/30/2019), discussed in general terms the Interim Final Ruling  and the changes that would become effective on March 25, 2020. Now that the Final Rule is in place...

We were honored to be interviewed for a recent story by The Wall Street Journal about the growing complexity of U.S. sanctions and trade compliance regulations.  The reporter, Mengqi Sun, asked good questions and did a great job portraying the compliance landscape faced by companies today. This statistic from the story is particularly interesting and...

No, Huawei is not the Godfather and Huawei with its subsidiaries do not constitute an Organized Crime Family, but the Department of Justice (DOJ) (Eastern District of New York) released a superseding indictment in its federal case against Huawei Technologies Co., Ltd. (“Huawei”). The superseding indictment consolidated and expanded upon earlier charges of bank and...

Are you Conducting Business with the Department of Defense? If your answer is “yes,” you’ll soon need to comply with the new standards based on the Cybersecurity Maturity Model Certification (CMMC).  Moi?  Yes, you.  Don't panic, there’s plenty of time to get certified, but you really need to get rolling now. Between June and September of...

Updated 1/18/2020 Asking The Right Question: Are You Trade Compliant? Very often, we talk with individuals who are focused on specific needs. They have questions like: “How do I get an ITAR license?” or “What is the ECCN for my product?” Although these questions are valid and important, sometimes companies need to take a step...

Updated 1/09/2020 Navigating The Confusing Landscape Of Distribution Statements Have you ever been frustrated or stymied by those DoD Distribution Statements concerning Critical Technology, which appear to prohibit U.S. contractors from sharing the data with their partners in Canada? If so, you’re not alone! Well, there is a way to work within the framework of...

I feel like it was just 1994 and the North American Free Trade Agreement (NAFTA) was ratified and I was hitting the road advising importers how to take advantage of the duty-free provisions. What a feat! U.S. industry had to learn the Rules of Origin, Tariff Shifts, Regional Value Content requirements and how to complete...

In a September blog “INCOTERMS, They are a-changing” , we discussed what potential changes could occur during the review process of INCOTERMS 2010 by the International Chamber of Commerce (“ICC”). The ICC has now released the latest revisions, which they believe will help simplify the responsibilities of the buyer and the seller in a trade...

On August 30th, BIS published Due Diligence Guidance regarding exports, re-exports, and transfers to Pakistan. With the increased concern regarding Pakistan’s nuclear program and risks of diversion, BIS is urging companies to conduct additional due diligence when it comes to transactions destined for Pakistan. The guidance highlights supplemental licensing requirements, as well as best practices...

Within a few short weeks, the International Chamber of Commerce (“ICC”) will release the much-anticipated INCOTERMS 2020 and, as it did in 2010, the publication of the ICC decisions will change the landscape of international trade.  As you may remember, the INCOTERMS were reduced from thirteen (13) to eleven (11) with the 2010 revisions. While...