On February 28, 2019, DDTC announced a consent agreement against Darling Industries. What has everyone talking, however, is what DDTC said about the company's Empowered Official.
If you’ve spent any time in trade compliance, you’ve probably come across the term “reasonable care.” But what, exactly, does that mean? Let’s review some practical ways to apply this principle to your global trade compliance program.
Late one Friday afternoon while speaking with a client who was about to leave on vacation, I heard the following question: “Do you know what a CF-28 Request for Information means?
Lately, everyone is focused on changes to U.S. export control regulations and related trade initiatives. And while the landscape is changing here in the United States, let’s not forget about China’s proposed new Export Control Law (“ECL”) which, although still in draft form, has passed the stage of public comments.
In recent weeks, we’ve seen significant activity from both the legislative and executive branches that could change the way foreign investment occurs in U.S. companies. Keep reading for a brief history of CFIUS reviews, and the proposed new legislation – FIRRMA.
Last week, FLIR Systems, Inc. entered into a Consent Agreement with Department of State, Directorate of Defense Trade Controls (“DDTC”) to settle 347 alleged violations of the ITAR. Keep reading for more details on what went wrong.
We field lots of questions about the difference between ITAR and EAR regulations, particularly with the changes from Export Control Reform in recent years. How can you distinguish ITAR vs. EAR?
Just like cooler temperatures and falling leaves are the harbingers of autumn, so too are the notifications that will soon be arriving from U.S. Customs and Border Protection (CBP) that your company has been selected for a Focused Assessment. What can you do to prepare for one of these assessments? How can you ensure that yours goes as smoothly as possible? Keep reading for some tips and guidance.
Have you ever struggled to determine the responsibilities and parties in a routed export transaction? If so, you’re not alone! Routed transactions make even the most experienced exporters pause. They have been described as dreaded, confusing, mysterious and complicated!
Earlier this month, DDTC published a new Consent Agreement with Bright Lights USA, Inc. of Barrington, New Jersey. This agreement alleges a variety of different ITAR violations, including technical data exports and failure to keep adequate records.