ITAR for Facility Security Officers
ITAR for Government Contractors - New Developments for 2018
License Exception MED - On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule for a new license exception for “medical devices” under § 740.23 of the EAR (“License...more
The US Department of Commerce’s Bureau of Industry and Security (BIS), which administers the Export Administration Regulations (EAR) and regulates most exports from the United States, announced further updates to the process...more
ACI’s highly anticipated Proficiency Series provides true immersion in the EAR with the objective of becoming proficient in four weeks. Join virtually from September 12 – October 5, 2023! Advance your career and...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) continues to send a strong and clear message to the exporting community – it wants businesses and universities to voluntarily disclose any significant...more
We wrote earlier this year about the growing web of regulation and enforcement attention around export controls. In another key development in this area, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”)...more
On Feb. 24, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a final rule amending the Commerce Control List (CCL) in part 774 of the Export Administration Regulations (EAR) to complete...more
On February 8, 2022, the US Department of Commerce’s Bureau of Industry and Security (BIS) added 33 Chinese entities to the agency’s Unverified List (UVL). The UVL does not fully prohibit transactions with the designated...more
The U.S. government recently took action in two cases against companies for exports to distributors that resold their products to prohibited parties. The products at issue in both cases are designated "EAR99," which is a...more
Please note: This Holland & Knight alert has been updated on Sept. 13, 2021, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two...more
The U.S. Foreign Military Sales (FMS) Program offers government contractors and suppliers to the U.S. defense industry valuable access to markets outside the United States and to bona fide customers in those markets. The FMS...more
Today, the Bureau of Industry & Security (BIS) is amending the Export Administration Regulations (EAR) to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption...more
There are two common types of aircraft exports: 1) permanent exports – where the aircraft is physically exported (i.e., flown) from the U.S. as part of a sale, lease or transfer of possession and control to a foreign person,...more
American Conference Institute (ACI) will host a one day virtual conference to discuss timely changes to the export controls regulations. Join key government officials, in-house decision-makers, and the “who’s who” of the...more
On August 17, 2020, the U.S. Department of Commerce Bureau of Industry and Security (BIS) made available for public inspection a final rule expanding restrictions on Huawei Technologies Co., Ltd. and its non-U.S. affiliates...more
On Monday, June 29, the Departments of Commerce and State announced that they were following through with changes to treat Hong Kong like China for exports of military and dual-use goods. The Department of Commerce announced...more
This software now requires a BIS authorization to be exported or reexported to all countries except for Canada. Companies that develop or use artificial intelligence (AI) to solve geospatial problems or in geospatial...more
It’s a problem that arises in many companies – you suddenly discover that an export violation may have occurred within your company. It might be a low level violation or it may be a more serious problem, such as the...more
The US State Department is soliciting feedback on its draft “US Government Guidance for the Export of Hardware, Software, and Technology with Surveillance Capabilities and/or Parts/Know-How,” issued September 4, 2019 (Draft...more
When shipping defense articles or dual-use items overseas, it is important to identify the actual end-user. This task cannot simply be outsourced to a freight forwarder. ...more
A set of changes to the U.S. dual use export control rules makes exporting sensitive goods, software, and technology to India less burdensome. Over the last several years, India has joined three of the four major...more
• The U.S. Bureau of the Census has issued a notice requesting comments on the definition of “routed export transaction” and the responsibilities of parties in routed export transactions. Comments are due by December 5, 2017....more
Beginning on April 19, 2017, individuals and companies planning to export to or re- export from Hong Kong will need to obtain certain paperwork prior to shipping. This new rule was published earlier in 2017, by the Department...more
Effective April 19, 2017, US exporters intending to export certain controlled items to Hong Kong will need to obtain, prior to shipment, either a copy of a Hong Kong import license or a statement issued by the Hong Kong...more
There are two major regimes that govern exports from the United States. One is the Export Administration Regulations (“EAR”) administered by the U.S. Department of Commerce’s Bureau of Industry and Security and, second, the...more
However, the new transaction rules leave the embargo largely in effect. Early this week, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and...more