It’s no surprise there are many opportunities for improvement among the current export control reforms being discussed in Washington D.C. However, I was recently reminded of a small – and (at least on the surface), simple – change that could alleviate a lot of confusion among U.S. exporters.
Here’s a quick lesson on compliance to the EAR regulations. If you’re going to import items from Cuba to the United States, then return them through your foreign subsidiary back to Cuba, well ... don’t do that.
Most people think of export violations related to weapons of mass destruction, anti-terrorism, and highly-technological items. But what about the illegal export of improperly-frozen chickens to Russia?
Earlier this week, I was updating our list of common ITAR exemptions and noticed that several have been added in recent weeks or months. Do some of these help your company comply?
The U.S. Bureau of Industry and Security (BIS) recently settled with Mattson Technology of Fremont, CA, in a case which alleges 47 EAR violations from 2006 to 2008. According to the order from BIS, Mattson “sold, transferred or otherwise serviced” pressure transducers “with knowledge that violations of the Regulations were about to occur or were intended to occur.”
What is ITAR compliance? It’s many different things, of course. However, if I had to choose two words to answer this question, they would be: Continual Improvement.
ITAR compliance is agreeably difficult, and exemptions are not “exempt” from this conundrum. Take, for example, the export of defense articles and technical data.
Earlier this month, DDTC made final a new exemption for certain exports to the United Kingdom in §126.17 of the ITAR. A quick look at the new 126.17 reminds me of the Canadian exemption (§126.5) in a number of ways.
Less than two months after they were added to the Excluded Party List System (EPLS), it now appears that the last of the freight forwarders have been removed from the EPLS – paving the way for a return to “business as usual” for exporters.
One of the big questions in the international business world is: “Are my products and/or data controlled by export compliance regulations?” The answer is ... YES! Most people are shocked to learn that nearly everything is export controlled.