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Exporters say: “Thanks . . . I Think?”

Be careful what you ask for. That is what some exporters are saying when deciphering the new BIS definition of “Specially Designed.” See language pasted below. Yes, this language is useful and long overdue, but it is certainly not intuitive or user friendly for those not well-versed in the terminology and logic of the EAR.

News From the OFAC International Trade Symposium

Last week the Office of Foreign Assets Control (OFAC) held its 3rd International Trade Symposium at the Convention Center in Washington DC. Adam Szubin, OFAC’s Director, opened the Symposium with descriptions of sanctions efforts regarding Iran, Syria and North Korea. He also highlighted two important new resources: a fuzzy logic Specially Designated Nationals (SDN) List search tool and an online application system for OFAC licenses.

Export Control Discussions at House Foreign Affairs Committee Hearing

On April 24, during a hearing entitled: “Export Control Reform: The Agenda Ahead, ”Acting Assistant Secretary of State Tom Kelly, Assistant Secretary of Commerce Kevin Wolf, and Defense Technology Security Administration Director James Hursch all testified before the House Foreign Affairs Committee. They discussed the goals and status of the President’s Export Control Reform (ECR) Initiative and answered questions on a variety of related topics.

Export Control Reform: Basics to Benefits

As we blogged on Tuesday, the final rules for the initial implementation of the President’s Export Control Reform (ECR) Initiative have finally been published. They will come into force on October 15, 2013, forcing exporters to get their compliance methodologies in order rather quickly. In the coming weeks, we will be blogging steadily, describing the reforms and how they can benefit our clients.

The 600 Series is Coming!

Major reforms are officially under way in the United States export control system. Many items that were considered Military in nature, and thus subject to stringent controls, will soon be re-classified. The aim of the reform is to move less significant Military items from State Department control to the Commerce Department where they will be subject to more liberal controls.

Final Rules Published for Initial Export Control Reform

The time has come. As promised, the Departments of Commerce and State have just published the final rules that will guide the initial implementation of the Obama Administration’s Export Control Reform.

UN Arms Treaty Reveals U.S. Divisions

Although the U.S. backed the new global arms trade treaty which recently won overwhelming approval in the UN, it was apparent before the gavel fell that ratification by the Senate will not be easy. Although the unprecedented treaty seeks to keep weapons out of the hands of human rights abusers, the powerful National Rifle Association gun industry lobby promised to fight against ratification.

Export Control Changes Debated in Satellite Industry

Regulatory change is never smooth or easy as evidenced by the pending export control reforms affecting the U.S. satellite industry. It will likely take another year for these reforms to take effect and already manufacturers are pushing for additional changes.

CTP Delivers West African Anti-Corruption Workshop

CTP was proud to oversee the first West African Anti-Corruption course at our new Regional Training Center in Accra, Ghana, welcoming delegates Ghana, Nigeria, Sierra Leone, Liberia and Tanzania. The goal was to discuss the impact of local and international anti-corruption and bribery legislation and its enforcement in West Africa.

“Capable of” Confusion

“Capable of” is a confusing phrase in the vernacular of the Commerce Control List (CCL).

Jurisdiction, Classification and Licensing: A Primer

Export control can be baffling to newcomers. It is a blizzard of acronyms, “defined terms,” and citations.

White House Pushing Export Control Reform

The White House announced changes designed to simplify the export licensing requirements for less sensitive items and simultaneously build more effective protections for the most critical technologies. The measures will simplify and streamline the export authorization process for thousands of parts and components used in aircraft and gas turbine engines, based on a more rational approach to the “specially designed” restriction.

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