I thought it might be time, to put the “legalities” of export controls aside, and instead, view these “controls”, whether they be BIS or OFAC’s, from the eye of the people that truly are affected-and I am not talking about American businesses, which though do have valid reasons to dispute unilateral embargoes placed by the […]

Posted on April 28th, 2008 by keeton
Filed under: News | Comments Off on Are OFAC embargoes truly worth the price in humanitarian costs?

As a result of the current economic climate, U.S. exports are increasingly on the rise—so, too, are the potential penalties that may be levied against violators of the U.S. export laws and regulations. Not only have the various U.S. government agencies responsible for administering U.S. export controls committed themselves to a renewed increase in their […]

Posted on April 18th, 2008 by keeton
Filed under: EAR, ITAR | Comments Off on The Stakes of Export Noncompliance

What constitutes a defense service, product, data, et. al. subject to the International Traffic In Arms Regulation (ITAR)? Question: Missile Defense Agency faithfully stamps all ITAR controlled data; and, if said data is not stamped, it’s not subject to or controlled by the ITAR. Is this correct ? Answer: No, it is the character and […]

Posted on April 14th, 2008 by keeton
Filed under: ITAR | 3 Comments »

Although most export applications submitted to the State Department are for hardware, the most important and complex cases are for defense services. “Defense service” and “technical assistance agreement” are terms the ITAR extends beyond the normal meaning of the words “service” and “assistance.” For example, if a U.S. defense company provides controlled technical data to […]

Posted on April 14th, 2008 by keeton
Filed under: ITAR | 1 Comment »

Notice anything missing? Legends and Markings If you have been in the business of exporting for any length of time, no doubt you have noticed that folks don’t pay much attention to marking their documents. Now I have seen a marked increase in the Company Proprietary legend, but the words Export Controlled seem to evade […]

Posted on April 14th, 2008 by keeton
Filed under: EAR, ITAR | 2 Comments »

Developments Regarding The “Deemed Export” Rule Within the panoply of governmental strictures encompassing the American export control world, two foundational legislative planks are the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). The ITAR imposes specific requirements and restrictions on how corporations may conduct business in the international marketplace even before […]

Posted on April 2nd, 2008 by keeton
Filed under: ITAR | Comments Off on Developments Regarding The Deemed Export Rule