When I was a kid, my father used to provide me with a wealth of important “life lessons,” doled out in simple one-liners that I could carry with me as I grew older. One of my favorites was “If you’re going to run with the pack, make sure you’re the leader.” Another that has served [...]
Posted on July 15th, 2008 by keeton
Filed under: ITAR | Comments Off
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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What is a DSP-73 Export License?
Other than the DSP-5 Export License, the DSP-73 is the type of license I hear referenced most often in the export compliance community.
The purpose of a DSP-73 license is to allow for the temporary (not permanent) export of controlled goods regulated by the Department of State. This means that [...]
Posted on June 4th, 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
Not too long ago, I helped to develop a compliance program for a well know defense contractor who’s business was the US sale of communications systems for commercial and military aircraft. Their primary issue was not licensing for the export of their products, but rather that their sales and marketing departments were in the [...]
Posted on May 22nd, 2008 by keeton
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While exporting grenade launchers to an unfriendly nation might be a cut and dried State Department licensing procedure, a more slippery and often significantly more treacherous export is that of technical data. With the evolution of the internet and an ever-shrinking world, this less tangible export is (in my opinion) far more dangerous to [...]
Posted on May 21st, 2008 by keeton
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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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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 content [...]
Posted on April 14th, 2008 by keeton
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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. [...]
Posted on April 14th, 2008 by keeton
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