Export Compliance News

What we’re talking about

Open General License (OGL)
Export Compliance News

Open General License (OGL) Pilot Program

The Open General License (OGL) Pilot Program has been implemented by the Directorate of Defense Trade Controls (DDTC) to ease licensing requirements for reexport and retransfer of unclassified defense articles to pre-approved parties in the United Kingdom, Australia, and Canada.  The current program is in effect from August 2022 to July 31, 2026, pursuant to

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Export Administration Regulations UVL
Export Compliance News

Export Administration Regulations UVL § 744.15

The Export Administration Regulations UVL (Unverified List) controls the export, reexport or transfer (in country) of items to listed parties. Furthermore, parties on this list are not eligible for any license exemptions. Failure to comply with these regulations can result in civil and criminal penalties, imprisonment, and debarment from export activities. Conducting Export Activities to

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CGP Cloud Solutions
Cyber Security

CGP Cloud Solutions Guidance – Technical Data

The government of Canada has specific Controlled Goods Program (CGP) Cloud Solutions requirements for individuals or organizations that possess or transfer controlled goods and associated technical data.  Technical data includes drawings, blueprints, software, or technical documentation that could be used or adapted for military or space end use.  Cloud service providers that provide storage or

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Voluntary Self Disclosure (VSD)
Export Compliance News

Voluntary Self Disclosure (VSD) Guidelines

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.  The three major sets of U.S. Regulations are the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and the Office of Foreign Assets Control (OFAC).   International Traffic in

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OFAC Non SDN Sanction
Export Compliance News

OFAC Non SDN Sanction List

The Office of Foreign Assets Control (OFAC) Non SDN Sanction List is a reference tool that is published by the United States Department of Treasury to identify persons subject to specific types of sanctions.  This list includes non-blocking prohibitions of the export specific goods and services and prohibitions based on statutory exceptions for imports.  The

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CGP Security Plan
Export Compliance News

CGP Security Plan Development Requirements

Canadian Controlled Goods Program (CGP) security plans are a requirement for work sites where goods are examined, possessed, or transferred.  This is a requirement for all companies registered in the CGP as described in section 10 of the Controlled Goods Regulations.   Controlled goods are primarily items, components and technical data that have been designated as

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300 Million Dollar Penalty
Export Compliance News

300 Million Dollar Penalty Imposed by BIS

A 300-million-dollar penalty was imposed on Seagate Technology, LCC, by the Bureau of Industry and Security (BIS).  These administrative penalties were leveled at the business’s operations in Fremont, California and Singapore and include a five-year suspended Denial Order, which if activated, would terminate the organization’s ability to conduct export business under the Export Administration Regulations

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Export Compliance Penalties
Export Compliance News

Export Compliance Penalties for ITAR and EAR

The U.S. Government continues to impose export compliance penalties for companies that commit violations.  This is the case for exports that fall under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).  These penalties can include both civil and criminal fines, imprisonment, and denial of export privileges. Penalties Under the ITAR

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ITAR-Expands-Treaty-Exemptions
Export Compliance News

ITAR Expands Treaty Exemptions for Transfers

The International Traffic in Arms Regulations (ITAR) expands treaty exemptions for the transfer of defense articles, services, and technical data enumerated on the Munitions List.  This rule, which will become effective on May 12, 2023, is in effect for transfers between the United States and Australia, the United Kingdom, and Canada.   Effect of Rulemaking This

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New DoD Requirement For Contractors
Export Compliance News

New DoD Requirement For Contractors

A new Department of Defense (DoD) requirement for contractors has been proposed.  This would require contractors to provide applicable export authorizations when receiving certain types of government contracts.  This proposed amendment to the Defense Federal Acquisition Regulation Supplement (DFARS) would empower the Defense Contract Management Agency (DMCA) to request export authorizations when contracts require Government

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BIS Addresses Human Rights
Export Compliance News

BIS Addressed Human Rights Through Entity List

The Bureau of Industry and Security (BIS) addressed human rights abuses with additions to the Entity List of individuals and organizations that are enabling or engaging in human rights violations.  The eleven entities added, in March of 2023, are based in China, Burma, Russia, and Nicaragua.  These actions demonstrate the ongoing efforts by the Department

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Microsoft export violations
Export Compliance News

Microsoft Export Violations Make News

Microsoft export violations have resulted in multi-million-dollar penalties for the software provider.  The company has made voluntary disclosures to the Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Assets Controls (OFAC), and the Department of Justice (DOJ).  Most of these reported violations occurred between 2012 and 2019.  These violations

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BIS Assessing Civil Space
Export Compliance News

BIS Assessing Civil Space Industrial Base

The Bureau of Industry and Security (BIS) is Assessing the Civil Space Industrial Base in the United States in partnership with the National Oceanic and Atmospheric Administration (NOAA) and the National Aeronautics and Space Administration (NASA) to better understand this important supply chain network.  This study will use surveys to collect data from U.S. organizations

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Disruptive Technology Strike Force
Export Compliance News

Disruptive Technology Strike Force to Enforce EAR

The Department of Commerce has initiated the Disruptive Technology Strike Force which will partner the Bureau of Industry and Security (BIS) with the Department of Justice (DoJ) in the enforcement of the Export Administration Regulations (EAR).  Export Administration Regulations (EAR) control the export of commodities determined to be dual-use.  Dual-use items refer to commodities and

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Export Compliance Program Guidelines
Export Compliance News

Export Compliance Program Guidelines – DDTC

The Directorate of Defense Trade Control (DDTC) has released Export Compliance Program Guidelines to provide businesses with an overview of best practices for complying with the International Traffic in Arms Regulations (ITAR).  These guidelines encourage organizations to adopt robust policies and procedures to ensure that compliance with export controls for items enumerated in the United

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ddtc open general license program
Export Compliance News

DDTC Open General License Program

The Directorate of Defense Trade Controls (DDTC) Open General License (OGL) pilot program has been instituted to ease the conditions under which exports, reexports, and retransfers of unclassified defense articles may be performed between pre-approved parties.  This program was started in August 1, 2022 and will continue through July 31, 2023, at which time the

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