The holidays are here, and many of us take this time of year to reflect on all that we have to be thankful for. If your company is registered pursuant to §122.1 of the International Traffic in Arms Regulations (ITAR), you may well be thankful that the new DECCS Registration Form and Process haven’t been implemented yet. However, all indications are that time is running out.
We all know the age-old Christmas tune, "The Twelve Days of Christmas." But have you heard the new one just released by Export Solutions? This catchy tune will not only have you humming along, but will keep you compliant throughout the year.
It’s almost Thanksgiving and when I think Thanksgiving, I think about traditions. In the spirit of traditions, here are five annual traditions your company should adopt when it comes to export compliance.
The policies and processes dictated by the DDTC as they relate to the administration of the ITAR have begun to change. The changes that have occurred and are about to occur relate to the process in which Registrations, License Applications, Advisory Opinions, Commodity Jurisdictions and Voluntary Disclosures are submitted to DDTC.
In a real baseball game, the players have the goal of staying at bat and not getting out, however, in the game of encryption, you are actually looking to get out. In particular, you want to determine if your item can “get out” of the Category 5 Part 2 controls.
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 finance contract. The latest version of INCOTERMS becomes effective January 1, 2020 and is to apply to contracts entered into after that date.
The U.S. Department of Commerce announced sanctions against twenty-eight Chinese governmental and commercial organizations for engaging in or enabling activities contrary to the foreign policy interests of the United States, by adding these organizations to the Entity List. The entities that were listed have been connected to human rights abuses with respect to China’s suppression of rights of the Uighurs and other predominantly Muslim ethnic minorities.
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.
DDTC has entered into a new Consent Agreement with L3Harris Technologies for violations of the ITAR. The $13 million penalty alleges 131 violations of the regulations. Keep reading for some of our observations about this case.
Does your Compliance Manual still define Defense Articles as “specifically designed, developed, configured, adapted, or modified for a military application”? Does it still contain two different Destination Control Statements? Regulations and government policies change. Your manual must stay current with those changes.