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Department of State Frequently Asked Questions

keeton — Sat, 18 Aug 2007 05:46:50 +0000

This guide contains answers to over 70 questions most often asked by exporters who are regulated by the Department of State and the US Government. It’s got useful advice, recommendations, technical answers, and more.

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Among the frequently asked questions, you’ll find:

“Why do I need to get the U.S. Governmentâ€™s approval to export and import defense articles and defense services?”

“How do I obtain approval before I export or import defense articles and defense services?”

“How do I know whether an article or service is controlled by the ITAR?”

“If Iâ€™m not sure what list my item is on, USML or CCL, how can I find out?”

“Who can apply for export or temporary import licenses?”

EAR, ITAR and EU Legal Compliance

keeton — Wed, 11 Jul 2007 17:07:42 +0000

Evaluation and Analysis

Governance
Documented Processes and Procedures
Analysis, Classification and Validation or product classification (ECCN) codes under ITAR/EAR and European Union legal guidelines

Risk Management
Active Products and Blocked Shipments
Customer contract fulfillment

Compliance
HEC and TEC Verification
Export Licensing Compliance and Management (SAP/GTS)

Export Compliance Manual Customization
International Consulting Company for Exporters

Chinese Spies – Confessions of a Defector

keeton — Mon, 09 Jul 2007 14:43:30 +0000

From EpcohTimes

During his recent visit to Canada, Chen Yonglin the Chinese diplomat who defected in Australia pointed out that the Chinese embassies in North-America control and use the Chinese Student and Scholar Associations (CSSA) for ulterior motives such as spying. More and more evidence for this Chinese embassy’s control has surfaced lately.

Your See Through Rule Blues

keeton — Thu, 05 Jul 2007 22:08:29 +0000

Q: What is all the fuss about this See-Through Rule?Â A: Letâ€™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) Â classified parts from commercial parts. Â Letâ€™s say you see a USML nut and bolt in there, but all else is commercial.Â Under the current interpretation of the See Through Rule, Export SuperPerson must now consider the entire engine as being Â under the USML jurisdiction. Â Or maybe not?Â This is the puzzling mud-pit known as the â€œSee Through Ruleâ€. Some call it â€œITAR Creepâ€ because of its slow moving and, well, creepy quicksand nature. Â It is when one bad ITAR apple spoils the whole bunch.Â Â

Brilliant analogies aside, the Rule considers products to be on the USML list if any part or component in the commercial dual use item is on the USML.Â

While tight export restrictions can be a good thing when it comes to protecting US technology from smarmy evildoers, industry, particularly the military industrial complex, is up in arms: Â ”globalization” efforts and sales of dual use equipment to China are frozen since, as we all know, USML parts or their related technology canâ€™t be sent there. It is also more costly, or even impossible to outsource production or to even export ITAR-tainted products for sale to other countries. Not to mention all that infected stuff out there was previously exported in more carefree days.

Thus, the industry argues, it will lose out against foreign competitorsÂ whoÂ aren’t impeded by Cold War era ITAR restrictions. So industry is still pushing for clarification of the see-through rule but the State Department won’t give it up just yet.Â A Big Chill was sent though the aeronautics industry a few years back when Boeing was fined $15 million because a USML classified QRS-11 navigation chip was included in a commercial engine exported for sale to

China.Â

Â The question is: just how far will the See Through Rule be applied? Â If State decides that the See Through Rule applies to all things, then there are lots of export violations floating around this planet which will be a world of bureaucratic hurt for US exporters. Â JRÂ

U.S. UK Technology Transfer Agreement Reached

keeton — Fri, 29 Jun 2007 22:48:48 +0000

The UK Ministry of Defence has brokered a bilateral agreement with its US State Department that would relax technology transfer restrictions thatÂ threatened London’s continued participation in the Lockheed Martin F-35 Joint Strike Fighter project. Read about it in Flight International USA

DDTC – Partial List of Arms Embargo Against Somalia

keeton — Wed, 16 May 2007 23:02:54 +0000

Â from ExportLawBlog.com

The Directorate of Defense Trade Controls (â€DDTCâ€) announced today that it was amending section 126.1 of the ITAR to reflect a partial lifting of the arms embargo against Somalia. These amendments are being adopted to implement revisions made to the Somalia arms embargo by U.N. Security Council Resolution 1744 adopted on February 21, 2007. Thee three month delay in announcing the amendments, which have not yet even been published in the Federal Register, indicates that revising the arms embargo on Somalia was not exactly put on the front burner at DDTC.

ReadÂ more at ExportLawBlog.comÂ

BIS Fines Supermicro Employee $60,000 for Exports to Iran

keeton — Fri, 27 Apr 2007 05:00:06 +0000

The Bureau of Industry and Security (â€BISâ€) recently released a settlement agreement in which Robert Abreu, the Senior Director of Strategic Sales for Supermicro Computers, agreed to pay $60,000 to settle charges arising from illegal exports of computer motherboards to Iran. The motherboards were shipped by Supermicro and Abreu to a distributor in the UAE which then re-exported the motherboards to

Iran

.Â

Read all about it on ExportLawBlog.com

Foreign Affairs – China’s Space Odyssey and Reliability As A Trade Partner

keeton — Thu, 26 Apr 2007 15:15:19 +0000

China’s Space Odyssey: What the Antisatellite Test Reveals About Decision-Making in Beijing
Bates Gill and Martin KleiberFrom Foreign Affairs, May/June 2007

Summary: China’s recent antisatellite test, which the military conducted while leaving civilian authorities mostly in the dark, raises a disturbing question: Will Beijing’s stovepiped bureaucracies prevent China from becoming a reliable global partner?

Read the article at ForeignAffairs.org

Latest Word On Bush’s Proposed Export Enforcement Act of 2007

keeton — Thu, 26 Apr 2007 05:27:24 +0000

ExportLawBlog cautions the Reuters News interpretation of the new Export Enforcement Act of 2007. A good clarification. Read it here.

PowerPoint Presentation on ITAR Industry Responsibilities

keeton — Thu, 26 Apr 2007 05:20:07 +0000

Early Christmas.. here’s a PowerPoint presentation given by Nancy Meyer, Supervisory Defense Trade AnaylstÂ fromÂ the US Department of State,Â at the series of International Traffic in Arms Regulations (ITAR) seminarsÂ in February and March 2006.Â The presentation providesÂ details on the administration of ITAR, and the responsibilitiesÂ industry have in complying with it. Posted at the Australian Industry, Tourism and Resources website

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