On February 24th, BIS issued a Federal Register Notice revising the Country Group designations for Russia and Yemen based on national security, foreign policy, and proliferation-related concerns. BIS stated that this action was “intended to facilitate and support accountability in connection with exports and reexports of items” to Russia and Yemen.
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.
The transition of Defense Articles from the ITAR (USML Categories I, II, and III) to the Export Administration Regulations (EAR) is here. Are you ready? The regulatory language has been circulated for comment, revised and re-revised for years, but now it’s final.
Despite the glib title of this blog article, we have been noticing a trend in companies using Freight Forwarders directed by their foreign customers. The goal, in many cases, seems to be for the seller to avoid being the “Exporter of Record.”
Let’s face it: the world is rife with export “experts.” One way to handle this is to ignore the problem, and pretend that ITAR compliance doesn’t matter. If you want to take this approach, it’s certainly your choice.Another option is to ask questions that will help separate the wheat from the chaff. These 10 questions come from my personal playbook. They’ll help filter out all but the best con artists, and they’ll also identify those consultants who think they know export compliance because their former employers sent them to a seminar last year.
Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine).
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 back and look at the bigger picture.
Many people focus on the need to obtain an ITAR license, without first considering whether or not an exemption may apply to their transaction. What is an exemption? Simply put, an exemption is a set of conditions which – if met – allow you to ship to your destination without the need to obtain an export license.
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!
The New Year is here and with the new year comes increased penalties for export violations. On January 3, 2020, the Department of Commerce published a Final Rule which adjusted the civil monetary penalty amounts for violations.