New Revisions to the EAR and ITAR to Harmonize Destination Control Statements

New Revisions to the EAR and ITAR to Harmonize Destination Control Statements   On August 17, 2016, as part of the President’s Export Control Reform initiative, the Bureau of Industry and Security (BIS) and the US Department of State issued final rules revising the destination control statement (DCS) requirements in the Export Administration Regulations (EAR) […]

$50,000 in ITAR fines

Last Thursday the Department of State issued a press release detailing charges and penalties levied against Alpine Aerospace Corporation and TS Trade Tech Incorporated of New Jersey. Both companies share common ownership and provide replacement parts to the aerospace industry. Violations: Failure to obtain proper export licenses Improper citation of existing licenses Failure to obtain […]

Export Enforcement Actions in 2007

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 […]

Are OFAC embargoes truly worth the price in humanitarian costs?

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 […]

Bananas and Terrorists Groups

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 […]

New ITAR Firearms Export Exemption in the Works

From ExportLawBlog: An article on the CTV website today revealed that Canada is considering a change in its Export and Import Permits Act to permit exempt imports and exports by law enforcement officers when they cross the U.S.-Canada border in the course of their official duties. Significantly this is said to be part of a reciprocal […]

Your See Through Rule Blues

Q: What is all the fuss about this See-Through Rule?  A: Let’s pretend you are Export Compliance SuperPerson with x-ray vision that can see through, say, an aircraft engine. Your uncanny sight can distinguish USML (United States Munitions List)  classified parts from commercial parts.  Let’s say you see a USML nut and bolt in there, […]

Report on Arms Export Compliance Violations

David Trimble, Director of Defense Trade Controls Compliance reports enforcement stats from February 2004 to February 2006: $60 million in fines 44 Debarments 12 Companies over direct oversight through ongoing consent agreements 459 Directed Disclosures Keep up the good work. Here is a slide show you can use in putting your presentation programs together. Use it […]

ATV Program and ITAR – from

  From – USA U.S. export controls governing the exchange of technical data have complicated matters for NASA and its partners as they prepare for Automatic Transfer Vehicle’s (ATV) debut. Now NASA has asked the U.S. State Department ifor space station-specific relief from U.S. International Traffic in Arms regulations that govern many space-related products […] Canada, U.S. reach deal on dual nationals’ access to American military goods reports that certain Canadian citizens with dual nationalities will have access to ITAR controlled technology. Read more here.