Export compliance can sometimes feel like a jigsaw puzzle that keeps adding pieces faster than you can find out where they go. In recent years, these regulations continue to change and become more complex. (Just count the pages in the Federal Register notices. They keep piling up!) Now more than ever, it’s crucial to understand…
It’s one thing to have your name in the news as part of a settlement agreement for export control violations. It’s quite another to be publicly called out by the government for apparently ignoring the new Russia sanctions. That’s exactly what happened earlier this month, when the Commerce Department issued a press release identifying dozens…
Tell me if this scenario raises any red flags. Your U.S. company produces complicated Industrial Microwave Systems (IMS). These systems can be used for things like food and beverage processing. With some modifications, they can also be used to create high-power directed-energy weapons systems. One day, you’re contacted by a representative from a company you’ve…
Unlicensed Exports Apply To All Foreign National Students It’s been several years since the imprisonment of John Reece Roth, a former University of Tennessee electrical engineering professor who was convicted of conspiracy, wire fraud and fifteen (15) violations of exporting ITAR controlled defense articles. Professor Roth was involved in a U.S. Air Force contract for…
Business Has Changed, It’s Time For Trade Compliance To Change, Too As the business world adapts to face masks, Zoom calls and social distancing, the trade compliance community is also re-evaluating the way it does business. While a lot has changed in your business, one thing that is certain to change – and, in fact,…
No one wants to really talk about trade compliance or acknowledge if it is lacking or non-existent. Not only is trade compliance an overwhelming and complicated mix of regulations, it is also something that puts most people to sleep! Often times employees think someone else is handling import compliance, but nobody is fully dedicated to…
“Hey Alexa, are you a U.S. Person?” Imagine this. A conference call with your foreign-based customer is about to begin. Today’s agenda includes technical discussions of recent upgrades and changes to the designs of some ITAR-controlled items. Your Trade Compliance Officer has reviewed the material and confirmed that export authorizations are in place approving the…
This is the second post in a series of blogs about the proposed changes to USML Categories I, II and III. Please check back for further articles in this series. For more information about these changes, and the movement of items from ITAR to EAR, check out Part 1 in our series and read the…
Like many trade compliance professionals, I go out and peruse various trade compliance newsletters, the U.S. government agencies websites, and other media to keep up-to-date on compliance issues. Recently, my attention was caught by a case involving Darling Industries of Tucson, Arizona. A closer look at Empowered Officials On February 28, 2019, the Directorate of…