Category: Violations

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…

On January 29,2020, Airbus SE of the Netherlands became another cog in the wheel of export enforcement. Airbus agreed to a settlement with DDTC of $10 million covering 75 violations of the Arms Export Control Act (AECA) and Part 130 of the ITAR for the time period 2011 through 2019. Outline of Violations The violations…

Updated 1/23/2020 Is Your Company’s Understanding Of ITAR Procedures Flawed? Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine): Export-controlled technical data has a unique set of rules designed to ensure that it is not inadvertently released or “exported” to…

The New Year is here and with the new year comes increased penalties for export violations pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Act”) became law in November 2015. The stated purpose of the 2015 Act is…

The Export Solutions blog provides timely and helpful information to anyone who is responsible for import/export compliance.  If you haven’t subscribed yet, join our growing community by subscribing now to stay current on all that’s happening in the world of trade compliance. As we say goodbye to 2019, let’s take a look at our top…

We are all familiar with the requirements of filing the Electronic Export Information (EEI) in the Automated Export System (AES); but let’s be honest- it may be a regulation, but it is more like an administrative process: you file the information and if you make a mistake, you amend it. No big thing. Maybe not……

DDTC has announced an administrative settlement (Consent Agreement) with the company, AeroVironment, Inc. for violations of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR) in connection with the unauthorized exports of defense articles, to include technical data, failure to properly maintain records involving ITAR-controlled transactions, and violations of the…

During all the activities (sanctions, tariffs, designated entities, etc.) of the past two months there was an updating of guidelines by Customs and Border Protection (CBP) that may have been overlooked. In July, CBP updated its Forfeiture Remission Guidelines for Export Control Violations.   Considering the fact that the last update was published in 2004, changes…

The Directorate of Defense Trade Controls (DDTC) has entered into a Consent Agreement with L3Harris Technologies, Inc. (“L3Harris”) for violations of the International Traffic in Arms Regulations (ITAR).  In its Proposed Charging Letter, DDTC alleged a total of one hundred thirty-one (131) violations.  The violations fall into the following categories: Unauthorized Exports of Technical Data…

The interim rule from the General Services Administration, the Department of Defense and NASA was published on August 7, 2019 and becomes effective today, August 13, 2019.  As a requirement of NDAA 2019, the rule prohibits federal agencies from purchasing telecommunications and video surveillance equipment, along with any “substantial or essential component of any system, or…