The Department of Homeland Security (DHS) announced on September 14, 2020 that forced labor goods from China are now banned.  The U.S. Customs and Border Protection (CBP) has issued Withhold Release Orders on products produced in China’s Xinjiang province.  In a statement Acting CBP Commissioner Mark A. Morgan stated that the forced labor goods banned

The Bureau of Industry and Security (BIS) places controls on technologies pursuant to Section 1758, whose export may threaten U.S. national security and foreign policy objectives.  As of May 23, 2022 the BIS announced that it would no longer classify those controlled technologies as emerging or foundational.  This action is providing the agency with flexibility

Exercising export regulations due diligence involves complying to complex sets of requirements set forth by multiple U.S. government agencies.  These agencies include the Bureau of Industry and Security (BIS), the Directorate of Defense Trade Controls (DDTC), the Office of Foreign Asset Controls (OFAC), and the National Nuclear Security Administration (NNSA). The International Traffic in Arms

The Bureau of Industry and Security (BIS) considers enforcement policies changes an instrument for combatting national security threats.  This was highlighted in remarks released from Matthew Axelrod, Assistant Secretary for Export Enforcement.  In recent presentations he outlined the changing focus of the United States export control system and the need for bolstering enforcement actions of

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 control laws.  Unfortunately, ignorance is not a defense when a party

The Bureau of Industry and Security (BIS) is placing controls on marine toxins in a unilateral effort to prevent biological threats to humans and the environment by way of accidental or deliberate release.  This control specifically addresses the export, reexport, or transfer of the biotoxins brevetoxin, gonyautoxin, nodularin, and palytoxin.  These toxins are generally found

Export Compliance Program Management Effective export compliance program management poses challenges for organizations of all sizes and sectors.  U.S. export regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) are complex and under constant revision.  Compliance is further complicated for organizations that have multinational operations and must therefore

ITAR and EAR- U.S. Export Regulations The ITAR (International Traffic in Arms Regulations) and the EAR (Export Administration Regulations) are export control regulations run by different departments of the U.S. Government.  Both are in place to ensure that restricted technologies do not get into the hands of terrorists and countries who are not operating in

Essential Features of an ITAR Compliance Program International Traffic in Arms Regulations (ITAR) compliance is a requirement for companies entering markets with defense related applications.  To establish an effective ITAR compliance program all segments of a business must be involved.  Important features of an ITAR program include the following: Registration with the Directorate of Defense

Continuing Changes in Export Compliance Maintaining export compliance programs presents challenges to organizations of all sizes.  Given the complexity of the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Antiboycott Regulations, and various sanctions, this is not surprising.  Additionally, international political events are forcing agencies to continually make changes to these regulations to

ITAR  Export Compliance Regulations International Traffic in Arms Regulations (ITAR) Export Compliance regulations control the export of articles that are developed for defense-related applications.  This includes items that are designed for military systems or intended for a military purpose.   The Directorate of Defense Trade Controls (DDTC), which is part of the Department of State, administers

ITAR Restricts Export to Cambodia The Department of State has amended the International Traffic in Arms Regulations (ITAR) to apply export restrictions on Cambodia.  The United States will now deny licenses and other approvals to export and import defense articles and services to Cambodia.  These restrictions, which became effective December 9, 2021 reflect a new

What is a Voluntary Self-Disclosure A Voluntary Self-Disclosure (VSD) is conducted when an organization recognizes that violations or suspected violations of Export Regulations of the United States have occurred.  This disclosure can reflect the organization’s due diligence in detecting, and correcting these violation.  When conducting a voluntary self disclosure to the federal government the following