Methods for Improving Ethical Trade Compliance of an Organization
Jarred A. Fishman
In an increasingly complicated and transnational business world, there is now greater importance than ever before placed on the ability of the export compliance regime to act in a positive ethical manner. This paper will seek to develop several themes. First I will discuss an [...]

Posted on June 6th, 2008 by keeton
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Below is a link to the US Department of Justice’s Fact Sheet: Major U.S. Export Enforcement Actions in the Past Year. Please pass it along to anyone who doesn’t believe that people ever get in trouble for export violations.
A few that stood out for me:

Excellence Engineering Electronics - Restricted Technology to China
ITT Corporation - [...]

Posted on May 22nd, 2008 by keeton
Filed under: EAR, Espionage, ITAR, News | Comments Off

On April 17, 2008, new legislation was introduced in the House of Representatives (”Securing Exports Through Coordination and Technology Act,” H.R. 5828) by Representatives Don Mazullo (R-IL) and Adam Smith (D-WA). This bill, which is intended to “enhance the reliability of information in the Automated Export System,” would significantly change the current AES filing environment. [...]

Posted on May 1st, 2008 by Melissa
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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
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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 the Header [...]

Posted on April 14th, 2008 by keeton
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Last month we discussed the Chiquita Banana case, the result of a voluntary disclosure and the consequences that resulted, including potential criminal charges by Columbian authorities for both the directors and officers involved—all due to a voluntary disclosure!
The debate on the pro’s and con’s of voluntary disclosures has been argued for years. During my tenure [...]

Posted on December 11th, 2007 by keeton
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The next time your cutting those banana’s for your morning cereal or having a banana-split at an Oberweis ice-cream shop keep in mind that you may just be indirectly supporting a foreign terrorist organization.
In the world of export compliance, corporate practitioners are constantly faced with issues from deemed exports to foreign nationals, to export [...]

Posted on December 11th, 2007 by keeton
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A commodity jurisdiction (CJ) needs to happen when a company exporting goods is either unsure whether their export is regulated by a government agency (the PMDTC in this case), or is unsure how to classify their good prior to export.
What I know about commodity jurisdictions

If you have to ask, your export will probably be considered [...]

Posted on November 29th, 2007 by keeton
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So, you export military goods to another country huh? I’m sure you do everything by the rules yourself, but how many people do you have in your organzation? Does your secretary know what ITAR regulations are? What about your warehouse people?
A common failure in many controlled export businesses is to forget to [...]

Posted on October 17th, 2007 by keeton
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Exporters of military and dual-use goods are first and foremost business people, and sometimes have the habit of skipping over the crucial export compliance steps between making the sale and delivering the product to their buyer.
Most often the results of this practice are slowed delivery schedules, government fines, and even restrictions on future exports. [...]

Posted on September 26th, 2007 by keeton
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