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DDTC Publishes FAQs on US Persons Abroad
On January 6, 2020 the Directorate of Defense Trade Controls (DDTC) published Frequently Asked Questions for guidance on the subject of US persons providing defense services abroad. The guidance addresses questions regarding registration and authorization...
Trade Associations Worried Over Impact of Reduced De Minimis Thresholds for China
By: Danielle Hatch There has been chatter that the Department of Commerce will be reducing the US-made content (“de minimis”) amount required for US reexports to be licensed to China. The change is said to be an attempt to squeeze Huawei even more past the addition of...
Wassenaar Puts Stronger Controls Cyber-Warfare Systems
In early December 2019 the Wassennar Arrangement held its annual plenary meeting and discussed stricter rules for software designed or modified for the conduct of military offensive cyber operations. Under the new provisions to Military List Item 21, this technology...
Census Updates Schedule B and Harmonized Tariff Schedule in AES
The Schedule B, Harmonized Tariff Schedule (HTS), and HTS Codes That Are Not Valid for AES tables have been updated in the Automated Export System (AES) and the system will now accept the codes. AES will continue to accept shipments with outdated codes for a grace...
Justice Department Publishes Enforcement Policy for Export Controls and Sanctions
By: Danielle Hatch In December 2019 the Department of Justice (DOJ) released a policy, through the National Security Division’s (NSD) Counterintelligence and Export Control Section (CES) that sets forth the criteria that will be used in determining solutions for...
Department of State Creates Definition of “Activities That Are Not Exports, Reexports, Retransfers, Or Temporary Imports”
The Department of State recently published an interim final rule requesting comments (must have been received by January 27, 2020) based on the idea of creating a definition of “activities that are not exports, reexports, retransfers, or temporary imports.” The...
DDTC Announces Commodity Jurisdiction Form Live
The new collection format for Commodity Jurisdiction form DS-4076 is now available on the DDTC DECCS portal. The changes address additional sources of jurisdiction considerations and refinements to the supporting information. All previous submissions to the...
Latest News on Transfer of Jurisdictional Control of Guns & Ammo from State to Commerce
By: Johanna Reeves, Esq., jreeves@reevesdola.com; Reeves & Dola LLP. www.ReevesDola.com On November 12, 2019, the U.S. Department of State notified Congress of its intention to transfer jurisdictional control of certain firearms and ammunition over to the U.S....
OFAC Updates Iran-Related FAQs
The Department of Treasury’s Office of Foreign Assets Control (OFAC) amended Iran General License (No. K-1) which caused OFAC to amend three Iran-related Frequently Asked Questions: FAQ 804 FAQ 806 FAQ 807 OFAC Notice:...
Secondary Sanctions’ Implications and The Transatlantic Relationship
By: Samantha Sultoon, Visiting Senior Fellow, press@atlanticcouncil.org; and Justine Walker, Sanctions Policy Director, UK Finance, press@ukfinance.org.uk The term secondary sanctions provokes strong reactions from allies and markets. Due to the power of the US...