Export Compliance, ITAR, and EAR
Export Compliance can be a daunting task, but recent events illustrate the importance of vigilance. On Tuesday, July 23, 2019 the Department of Justice indicted four Chinese nationals and a Chinese company for conspiracy to defraud the United States and evade sanctions. The indictment alleges that the defendants sought to obscure illicit financial dealings for sanctioned North Korean entities. These entities were involved in proliferation of weapons of mass destruction.
In the Department of Justice release, Assistant Attorney General Benczkowski was quoted as saying “Any Chinese company conspiring to do business with sanctioned WMD proliferators through the U.S. banking system should think twice.”
This incident is among many that show that the federal government is serious about export compliance. All applicable agencies have therefore been very diligent in their enforcement of late.
Export Compliance and Your Company
This situation clearly shows the need for adequate screening of all of a company’s potential customers and contacts. Hostile governments will use any means possible to accomplish their ends. Export compliance is therefore crucial for mitigation these threats.
Financial and technical enterprises are especially at risk for export compliance violations. Because of this caution should be used in all business interactions. Even an inappropriate phone conversation can be deemed an export if it relates to the technology of a controlled product. Appropriate procedures must be in place to prevent illegal actions and reiterative training to keep all employees on guard.
If you are part of a large corporation with an ITAR or EAR compliance related employees or a small company with a part-time compliance person, CVG Strategy has the compliance and training programs to fit your exact needs. Often smaller businesses often don’t have the bandwidth to dedicate to adequate export compliance. Because of this we offer outsourced Export Compliance Officer services.
CVG Strategy, LLC is recognized the world over as the premier provider of customized ITAR Consulting and ITAR & Export Compliance Programs and Training that addresses critical U.S. Government regulations, from Export Administration Regulations (EAR), to the International Traffic in Arms Regulations (ITAR) and Office of Foreign Asset Controls (OFAC) and other regulatory agencies and more.