Export Compliance News

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foreign based businesses
Export Compliance News

Foreign Based Businesses and U.S. Export Compliance

Foreign based businesses and persons involved in the reexport of items controlled under the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) are subject to the regulations and associated sanctions.  This also holds true for foreign producers of items that incorporate threshold percentages (de minimis) of controlled items in their products

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Disruptive Technology Task Force Enforcement Actions
Export Compliance News

Disruptive Technology Task Force Enforcement Actions

The Disruptive Technology Task Force was launched in February of 2023 by the Department of Commerce, the Department of Justice, and the Federal Bureau of Investigation in an effort to prevent the unlawful acquisition of advanced technologies by foreign adversaries.  To date this effort has resulted in numerous cases being filed against parties involved in

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Export Administration Regulation Developments
Export Compliance News

Developments in Export Administration Regulations for 2024

As 2024 begins, it will be interesting to note how developments in Export Administration Regulations (EAR) will unfold.  The previous year has seen tightening of export controls, increased enforcement activities, increased penalties, and co-operation of the Bureau of Industry and Security (BIS) with enforcement agencies in this nation and abroad. What are Export Administration Regulations

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BIS Export Controls and the CCP
Export Compliance News

BIS Export Controls and China

A 2023 report from the U.S. House of Representatives stressed the importance of Bureau of Industry and Security (BIS) export controls to mitigate threats economic and national security threats from China.  The bipartisan report stressed that China is using military, economic strength, and it technological base to further an agenda of global domination.  It further

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Export Control Classifications
Export Compliance News

Export Control Classifications & Due Diligence

Performance of export control classifications is a requirement for businesses conducting sales of products and services, even if the sale is conducted within the United States, because the customer may be a non-U.S. person.  Classification of products provides a determination that a proposed transaction is allowed under federal regulations, is prohibited, or requires licensing or

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National Security Guardrails for CHIPS
Export Compliance News

National Security Guardrails for CHIPS

The National Security Guardrails for CHIPS have been established by the U.S. Department of Commerce in an effort to prevent manufacturing subsidies for semiconductor manufacturing from being diverted into nations considered to be national security threats.  The CHIPS and Science Act, originally published in March of 2023 is an incentive to enhance global supply chain

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Technical Assistance Agreement (TAA)
Export Compliance News

Technical Assistance Agreement (TAA) and ITAR

A Technical Assistance Agreement (TAA) is a requirement under the International Traffic in Arms Regulations (ITAR) when an organization exports a defense service, technical data, or the assembly of a defense article.  A defense article is defined as an item or technical data that is enumerated in the United States Munitions List (USML).  Other important

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Export Law and Immigration Discrimination
Export Compliance News

Export Law and Immigration Discrimination

Integrating compliance of export law and immigration discrimination requirements under the Immigration and Nationality Act (INA) can be challenging.  Employers who export items controlled under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) must prevent the deemed export of technical data to non U.S. Persons while avoiding employment discrimination.  Recently, both SpaceX

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CUI Document Marking Requirements
Cyber Security

CUI Document Marking Requirements and CMMC 2.0

Controlled Unclassified Information (CUI) document marking requirements apply to a wide range of users who access information related to the U.S. government. CUI  is unclassified information that requires safeguards or dissemination controls in accordance with governmental regulations and policies. CUI is categorized into 20 “Organizational Index Groupings” to address sectors such as Defense, Export Control,

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Managing an Export Compliance Program
Export Compliance News

Managing an Export Compliance Program

Managing an Export Compliance Program (ECP) properly ensures its effectiveness.  These programs are essential to the sustainability of a business.  However, any plan, no matter how well conceived, is only as effective as its execution.   Planning the Export Compliance Program Specific requirements for an Export Compliance Program are contingent on the types of products an

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Training for Export Compliance
Export Compliance News

Training for Export Compliance – ITAR and EAR

Regular training for export compliance is more important than ever.  This is due to dynamic changes in export regulations and increased enforcement of those regulations.  CVG Strategy offers up to date training for Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR).  Our training is interesting and engaging for participants and allows ample

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Antiboycott Reporting and Compliance
Export Compliance News

Antiboycott Reporting and Compliance Changes

Matthew S. Axelrod, Assistant Secretary for Export Enforcement at the U.S. Department of Commerce, released a memorandum July 26, 2023, announcing changes in antiboycott reporting and compliance requirements.  This announcement follows a series of similar memorandums from the Department of Commerce that have increased the intensity of export enforcement actions. History of U.S. Antiboycott Regulations

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Voluntary Self-Disclosure Policy Updates
Export Compliance News

Voluntary Self-Disclosure Policy Updates

Voluntary Self-Disclosure policy updates were issued jointly by the Department of Commerce, Department of Treasury, and the Department of Justice.  Under the moniker of Tri-Seal, the three agencies provided information about the self-disclosure process for violations of sanctions, export regulations, and other national security laws. These three agencies have been increasingly coordinating efforts to prevent

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Five Eyes Export Control Agreement
Export Compliance News

Five Eyes Export Control Agreement

A Five Eyes export control agreement seeks to enhance the security concerns of Australia, Canada, New Zealand, the United Kingdom, and the United States by formally committing to coordinate export control enforcement efforts.  Matthew S. Axelrod, Assistant Secretary of Commerce for Export Enforcement, stated that this will result in detentions, public identification, and penalties for

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DoD Addresses Foreign Influence
Export Compliance News

DoD is Addressing Foreign Influence in Academia

The Department of Defense (DoD) is addressing foreign influence in academia with the publication a foreign entities list that includes threats to U.S. national security.  This was announced in an address from Heidi Shyu, Under Secretary of Defense for Research and Engineering (USD R&E).  By adding this requirement for screening of potential partners, the Pentagon

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DOJ Stressed Export Compliance
Export Compliance News

DOJ Stressed Export Compliance Diligence

During a recent address at the Ethics and Compliance Initiative Impact Conference, Marshall Miller, the Principal Associate Deputy Attorney General at the Department of Justice (DOJ), stressed Export Compliance diligence in ensuring compliance with export regulations.  He further stated that as the agency continues enforcement efforts connected to United States national security investigations that they

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