Last month, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to reflect the removal of the United Arab Emirates (UAE) from the list of countries participating in the Arab League Boycott of Israel. The final rule deems certain requests for information, actions or agreements made before August 16,2020 which were…
Last week, the U.S. Department of Justice announced that a former Raytheon engineer was sentenced to 38 months in prison for violations of the Arms Export Control Act (AECA). According to the press release, Wei Sun, 49, pleaded guilty to one felony count of violating the AECA. He was sentenced by District Court Judge Rosemary…
Does My Business Need Help With Global Compliance? When it comes to international business, every move you make counts. Exporters often need assistance at various stages of the exporting process- from building a complete program to getting products out the door. Deciding where to begin and who to contact can be difficult, and not least…
This past week, the Trump administration announced a ban on exports of certain types of Personal Protective Equipment (PPE) in response to the COVID-19 crisis. The new rule became effective immediately and will last four months (until August 8, 2020). While this type of activity is unusual due to its breadth and scope, those of…
The New Face Of ITAR Compliance For Your Business 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…
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…
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 essential, sometimes companies need to step back and look at…
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? Distribution Statements are technical documents If so, you’re not alone! While Distribution Statements seem overwhelming, at…
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…