Defense Trade Controls, Export License, ITAR, TAA, USA Regulations
Updated: April 25, 2023 By: Maarten Sengers and Scott Gearity Continuing on the theme of International Traffic in Arms Regulations (ITAR) contradictions begun in last month’s newsletter, let us turn to another ITAR contradiction that has resulted in tremendous and...
EAR, ECCN, ITAR, License Exceptions
On the Commerce Control List (CCL), items controlled in the 600 series (those with a “6” as the third character of the ECCN) are military items, most of which were previously controlled on the United States Munitions List (USML) and subject to the ITAR. Such sensitive...
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...
