Our “EAR”... to the ITAR
Answers to your questions about U.S. export controls
from
ECS expert trainers and consultants.
In separate, but related, December actions, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published new sanctions lists largely aimed at companies tied to the Chinese military. The new lists build on the 2020 releases of the Department of Defense list […]
We have a handful of developments out of the Commerce Department, with revisions to controlled items, human rights review, and license extensions. At the end, there are two developments out of Middle East Commerce Implements 2018 & 2019 Wassenaar Revisions On September 11, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) published […]
Waiver May Permit Non-Lethal Exports to Cyprus On September 28, 2020, the Department of State, Directorate of Defense Trade Controls (DDTC), published an amendment (85 FR 60698) to the International Traffic in Arms Regulations (ITAR) updating the defense trade policy towards the Republic of Cyprus. Cyprus is listed as a prohibited destination, with certain exceptions, […]
Huawei Restrictions Expanded On August 20, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) published a rule (85 FR 51596) which added thirty-eight non-U.S. Huawei affiliates to the Entity List, removed a temporary general license for Huawei, and amended the Direct Product Rule. The listing of thirty-eight Huawei affiliates is in addition […]
On August 27, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) released an advance notice of proposed rulemaking (ANPRM) (85 FR 52934) requesting public comments on potential controls for “foundational technologies.” This inquiry is based on the Export Control Reform Act of 2018 (ECRA) which requires the Department of Commerce to establish […]
On July 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) published a request for comments (85 FR 43532) on Commerce Control List (CCL) items controlled for crime control and detection (CC) reasons. CC controls are intended to promote human rights throughout the world by restricting the export of products that can […]
It may be summer and COVID-19 is still impacting everyone, but it is not a time to stop paying attention to export compliance! The U.S. Government is working away updating policies, expanding services and asking for your comments on export controls. Unmanned Aerial Systems Policy Adjustment On July 24, 2020, the White House announced a […]
In our last post, we covered a series of breaking developments in export compliance towards China and Hong Kong. While those developments have received a lot of attention, summer has brought us even more export compliance updates. New CCL Chem/Bio Controls On June 17, 2020, the Department of Commerce, Bureau of Industry and Security (BIS) […]
On June 24, 2020, the Department of Defense released the following list of “Communist Chinese military companies”: Aviation Industry Corporation of China (AVIC) China Aerospace Science and Technology Corporation (CASC) China Aerospace Science and Industry Corporation (CASIC) China Electronics Technology Group Corporation (CETC) China South Industries Group Corporation (CSGC) China Shipbuilding Industry Corporation (CSIC) China […]
On June 5, 2020, the Department of Treasury, Office of Foreign Assets Control (OFAC), published a final rule (85 FR 34510) establishing the Syria-Related Sanctions Regulations (31 CFR Part 569), which implement Executive Order 13894. The new regulations are in addition to OFAC’s existing Syria Sanctions Regulations (31 CFR Part 542). Although titled “Syria-Related Sanctions,” […]