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 those of you in the crude oil exporting business, life has just gotten a little bit easier. The CCL entry (ECCN 1C981) requiring a BIS license to export crude oil out of the United States has now been removed and the new classification will be EAR99. Last month, a rule was issued by BIS…
A Florida woman, Amin Yu (a/k/a Yu Amin, a/k/a Amy Yu) was charged in a superseding indictment with conspiring to illegally export U.S. technology to a Chinese state-owned entity. This technology is used in underwater drones. Among other charges in the indictment (including illegal exports, money laundering, and acting as an agent for a foreign…
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…
Let’s assume that you’re traveling internationally with your ITAR-controlled product and you have a valid DSP-73 license in place. (If I’ve already lost you with that sentence, then please skip the rest of this article and schedule a no-charge consultation with us today.) Requirement Area What the Requirement Says Why It Matters / Key Risk…
EAR- Don’t Forget About The De Minimis Rule One of the lesser-understood rules in the Export Administration Regulations (EAR), is the de minimis rule, which determines whether foreign-made products that incorporate U.S.-controlled content are subject to the EAR. While making international trade easier and better defining the jurisdiction and classification of items, the Export Control…
Looking for someone to conduct a gap analysis of your trade compliance activities? Consultants come in all shapes and sizes, with various backgrounds, skills and expertise. But not all consultants (or their assessments) are created equal! Before you give that consultant a green light, make sure you have a thorough understanding of what they’ll be…
You may find your customers asking if your products qualify for NAFTA or if you can provide a NAFTA certificate. The logical questions that follow are: “What is NAFTA?” and “What is a NAFTA certificate?” In this blog, we’ll provide a basic overview of NAFTA in order to help with your understanding of this topic….
HTS Chapter 98 And Your Business Savings and more savings on duties and fees are available for exporters who import their U.S. goods back into the United States. These savings are not BOGO (buy one, get one). Rather, they are for all U.S. goods returned (and some Non-U.S. goods). Have you ever reviewed Chapter 98…