Export Compliance News

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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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EAR Export Administration Regulations Requirements
Export Compliance News

EAR Export Compliance Program Requirements

Recent enforcement activities by the Bureau of Industry and Security (BIS) illustrate the importance of having a viable Export Administration Regulations (EAR) Export Compliance Program.  These events including a 300-million-dollar penalty imposed on Seagate Technology earlier this year, are as Assistant Secretary for Export Enforcement Matthew Axelrod described, “a clarion call” for businesses to comply

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BIS Restrictions on technologies to PRC
Export Compliance News

BIS Restrictions on Technologies to PRC

BIS restrictions on technologies to the PRC are being put in place to limit China’s ability to enhance its military capabilities, according to Thea D. Roxman Kendler in testimony to the Senate Banking, Housing, and Urban Affairs Committee.  Roxman is the Assistant Secretary of Commerce at the Bureau of Industry and Security (BIS) in charge

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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

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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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