QUESTION: One of our ITAR/EAR-controlled facilities is sharing office space with a sister company foreign national employees. The employees have access to our facility and share our break room and restroom areas. There is no outside entrance upstairs, so the employees have to access yellow line only areas to get to there work area. What […]
QUESTION: Does anyone know if there’s a recent annotated EAR? I have one for ITAR and FTR but haven’t found a recent one for EAR. ========== Answers: Not sure what you mean by “annotated”. The “live”, current version with all updates is always at the ecfr site: https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=%2Findex.tpl ========== https://www.ecfr.gov/cgi-bin/text-idx?node=pt22.1.121 ========== I personally have never […]
QUESTION: There is a company on the Entity List, and we want to sell some EAR99 goods (nothing listed in 15 CFR 746.5’s ECCNs or HTS numbers) to them in Vietnam, but the bank involved is refusing to process the funds. The bank tells me that they cannot tell me why they refused the transaction […]
QUESTION: We have a current customer that wants to be a Distributor is Russia. Since Russia has many sanctioned individuals, I want to ensure we are in compliance and have done our due diligence . The items they will be purchasing are not controlled under EAR or ITAR. We screen all our customers, vendors, […]
QUESTION: According to EAR 742.8, it appears EAR99 items are allowed to export to Iran if the end use or end user is not mentioned in the regulation or found as a restricted party. In addition to, if the commodity is not noted in Part 746.7. However, I am not too sure about OFAC 560.201.205? […]
QUESTION: We recently received the commodity classification result from the BIS for our NEW software that will be used for our devices. The result is ECCN EAR99 which basically means we are now free to do anything with the software, except sending them to the US embargoed countries. The OLD software was previously classified by […]
QUESTION: If items subject to the EAR are exported to Country A and then subsequently re-exported to Country B, is the re-exporter required to include the Destination Control Statement on their export paperwork? ========== Answers: If the items are U.S. origin, yes. Do companies overseas adhere to it? Most likely not, but I am seeing […]
QUESTION: We have filed EEI for EAR99 product. After vessel’s departure customer has requested to change the final destination of the container within the same country. If we process with COD request, should we amend EEI filing (post departure) to reflect the correct discharge port? Will it be considered a compliance issue? We are concerned […]
QUESTION: I found out that equipment that my product is used in as an “attachment” is on the CCL Alphabetical Control List and has an ECCN number but my product is not on the Alphabetical Control List. While I do not see the name of my product on the Alphabetical Control List would it be […]
QUESTION: The scenario is shipping automotive parts, US finished goods(EAR99) to a subsidiary located in the EU. I have read through 31 C.F.R. 560.215 showing prohibitions to Iran. There is an exemption under General License H that allows you to ship items that don’t have a license. However, on Oct 13, 2017 President Trump chose […]
QUESTION: I am working with senior leaders in our company to establish an HR policy on hiring of foreign persons. The company has recently consolidated a number of separate entities under a single company here in the US. We are incorporated in the US, but foreign owned and ITAR registered as a manufacturer / exporter. […]
QUESTION: Does the Export Administration Regulations state anywhere that one dedicated individual needs to be named as a point of contact relating to export functions for a company or corporation? ========== Answers: No. ========== Refer to 30.6 (iv) of the FTR “USPPI contact information. The person who has the most knowledge regarding the specific shipment […]
