Commerce Department regulations that gave Hong Kong Special Status have been suspended.  U.S. Secretary of Commerce Wilbur Ross made this announcement on June 29, 2020.  This change will effect the export of sensitive U.S. technologies to Hong Kong.  It will also effect the availability for export license exceptions. Mr. Ross also mentioned that further actions

Export regulations due diligence is a somewhat vague term given the gravity of maintaining an export compliance program.  It is no easy task to determine product classifications, obtain licenses, and screen potential customers. Bureau of Industry and Science and Export Administration Regulations The Bureau of Industry and Security (BIS) manages Export Administration Regulations (EAR).  The

The U S Restricts Huawei’s Semiconductor Manufacturing Capabilities The U S will Restrict Huawei semiconductor manufacturing by limiting the use of technologies for design and manufacture.  This planned action was announced by the Bureau of Industry and Science (BIS) on May 15, 2020.  The BIS is implementing this action to protect national interests by preventing

FEMA Temporary Ruling on Allocation of Personal Protective Equipment (PPE) A Federal Emergency Management Agency FEMA ruling on medical resources will be effective until August 10, 2020. This action has been taken in response to the immediate need for Personal Protective Equipment (PPE) caused by the COVID-19 epidemic.  Recent studies have shown that COVID-19 is

The Importance of Understanding Export Administration Regulations (EAR) Understanding Export Administration Regulations is especially important for businesses today because of the prevalence and ease of conducting international trade in today’s world.  Many businesses learn too late the consequences of remaining ignorant of federal export laws.  Unfortunately, ignorance is not a defense. Title 15 of the

Export Compliance Program Management Effective export compliance program management is important for a successful business.  International trade is more prevalent than in any time in history.  Failure to comply with export laws such as the Export Administration Regulations (EAR) and the International Trade in Arms Regulations (ITAR) can lead to criminal penalties and imprisonment, civil

Huawei’s Legal Problems in the United States Huawei’s Legal Problems in the United States continue on multiple fronts.  The Chinese tech giant has been the target of the U.S. Senate, The Department of Justice, and has had a case against U.S. Government contracts ban dismissed before going to court. Department of Justice Actions In an

Airbus ITAR and Bribery a Massive Multi-year Scheme The Department of Justice recently announced that Airbus ITAR and Bribery Penalties would amount to more than $3.9 Billion in fines to the United States and United Kingdom.  Airbus, based in France, is a leading global manufacturer of commercial and military aircraft.  This case, which involved the

Continuing Changes in Export Compliance Maintaining export compliance requires vigilance and is more important than ever.  The Bureau of Industry and Security (BIS) has increased enforcement and has also increased civil and criminal penalties for export violations.  At the same time changes in sanctions and Export Control Classification and the U.S. Munitions List (USML) make

New EAR Export Restrictions of Geospatial Software The Bureau of Industry and Science placed restriction on the export of geospatial software on January 6, 2020.  This ruling classifies software specially designed to automate the analysis of geospatial imagery, as specified, under the Export Control Classification Number (ECCN) 0Y521 series, specifically under ECCN 0D521.  This ruling

Changes in ITAR Definitions The U.S. State Department has made changes in important definitions of what constitutes an export under the International Trade in Arms Regulations (ITAR).  These changes are due to take effect on March 25, 2020 and will effect the manner in which companies with ITAR classification must conduct business.  These definitions concern

ITAR Requirements (International Trade in Arms Regulations) ITAR Compliance places requirements on companies entering markets with defense related applications.  To establish an effective ITAR program all segments of a business must be involved.  Important features of an ITAR program include the following: Registration with the Directorate of Defense Trade Controls (DDTC) Establishing an Export Compliance

Do you need to file a Voluntary Self Disclosure? Many companies face the challenge of whether or not they need to file a Voluntary Self Disclosure when they recognize a violation of US Export Law at their company.  Violations of US Export Law for the Export Administration Regulations (EAR) and International Trade in Arms Regulations