EAR, Export Compliance, Export Controls, ITAR, US
It comes as a surprise to many that certain activities governed by U.S. export control regulations don’t necessarily involve sending things out of the United States. And among those who already know this, many believe there are requirements to follow which, in fact,...
Export Controls, Foreign Direct Product Rule, ITAR
How can the United States claim export control jurisdiction over an item that isn’t made in the United States, doesn’t contain any U.S.-origin content, and is traded between parties in other nations without ever touching U.S. territory? That’s the idea behind the...
BIS, Denied & Restricted Parties, Export Compliance, ITAR
It’s impossible to conduct a meaningful transactional export compliance process without running into the alphabet soup of restricted party lists. Here’s an overview of the lists most likely to come up and how they’re used. Entity List What’s affected: Exports,...
Hardware, ITAR, License Exceptions, Software
Hardware and software that incorporates encryption is a much larger category of exports than most people realize. That’s because just about anything that contains some sort of encryption capability – even if it’s ancillary to the item’s primary function – needs to be...
Aerospace, Export Compliance, ITAR, News, Russia, Sanctions, Ukraine
The invasion of Ukraine resulted almost immediately in a range of new license requirements for exports to Russia. (See Feb. 28 blog post, The Russia-Ukraine War: EAR Updates You Need to Know.) The new export controls, detailed in the Federal Register, cover Categories...
Certification, EAR, Export Compliance, ITAR
Businesses dipping their toes into export activities will inevitably run into regulatory considerations arising from the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR), or both. Not only can non-compliance subject...