This past July, the Bureau of Industry and Security (BIS) recently issued guidance on addressing both export controls and diversion risks. (Diversion risk refers to the potential for items, technology, or services to be redirected or transferred to unauthorized end-users or end-uses, which can violate export control laws and regulations). The guidance outlines various actions BIS…
In a previous blog, we discussed the concept of “reasonable care” as it applies to your trade compliance program. The focus was how export and import programs dovetail with many other areas of compliance, such as policies and procedures, valuation, Free Trade Agreements, and more. Today, I’d like to switch gears and talk about how…