Effective October 14, 2016, BIS has amended the Export Administration Regulations to allow for electronic submission of reporting requests U.S. persons receive to take action in furtherance or in support of an unsanctioned foreign boycott. Prior to this, reports were only permitted to be submitted by mail using BIS 621-P or BIS 6051-P.
Traditionally Export Related Voluntary Disclosures/Voluntary Self-Disclosures have been filed with DDTC, BIS, OFAC or occasionally the Bureau of Census. Each of these agencies encourages companies and individuals to file the Disclosures and they provide an incentive in that the filing can be considered as a mitigating factor to the violation(s) committed.
Moving one step closer to the Single IT system goal of Export Control Reform, DDTC has acquired a new case management IT system to modernize its business processes. Additionally, DDTC has begun accepting comments related to the new DS-7788.
In March of 1983, during a speech in Orlando, Florida, former President Ronald Reagan first used the phrase the “evil empire” to describe the Soviet Union. The phrase stuck, and a new era of emphasis on Export Regulations and Controls began.
The clock is ticking! Exporters have just one month (until November 15, 2016) to change the language and use of their Destination Control Statements (DCS).
Here’s a question we see all the time: We’re registered as a manufacturer of defense articles, but we do not export. So, why do we need a compliance program with written policies and procedures?
Earlier this month, I was reading some articles online and found the following statement about a company and its ITAR requirements (bold emphasis mine).
Through Executive Order, the President has ensured that the EAR will continue for another year.
The U.S. Bureau of Industry and Security (“BIS”) recently issued administrative settlement documents against a company called Fulfill Your Packages ("FYP"). Under the settlement agreement, FYP agreed to pay a $250,000 fine, of which $190,000 was suspended on the condition that the company has no export violations over the next two years.
For any industry, the “cost of doing business” inevitably increases over time. For companies engaged in ITAR-controlled work, the cost of not doing business compliantly is about to skyrocket.