Question: Hello Membership – We are exporting unassembled kits where, if exported assembled, would be EAR99 [per § 770.2(b)(1)], however, some components have an ECCN. I know that per § 770.2(b)(1) if we export a unit of equipment that contains parts with licensable content that we can export under without a license if that unit […]
Question: We are putting together a Technology Control Plan as the items under our services are considered controlled (ECCNs 5Axxx, 9Axxx, 7Axxx for example). Due to the layout of our facilities, our repair operations is an open floorplan and we are working to figure out the best way a foreign national could be identified so […]
Question: Hello all, I have two questions. As we know, only the United States uses the EAR99 classification. Suppose a foreign-made item falls below the de minimis threshold and is thus not subject to U.S. jurisdiction; what classification should be used in a foreign jurisdiction where the concept of “EAR99” does not exist? Should we […]
Question: If my company imports goods into the US and resells to an overseas company who will immediately export the goods from the US as FPPI and my company as USPPI. Does there need to be a markup on the sale from my company to the foreign company to meet the definition of “financial interest […]
Question: Can someone please share an example of a voluntary disclosure template for export purposes? Answer 1: You didn’t say what agencey – BIS, DDTC, OFAC, Census…they each differ, but at the same time clearly provide the “template”. For example see 764.5(c) of the EAR. Answer 2: I used the following template to provide a […]
Question: Hi. My company is requesting that we begin to collect ITN information on routed transactions in order to match up with ACE. This hasn’t posed a problem for 2024, but my company is asking me to find ITNs for thousands of routed transactions dating back as far as 2020. Understandably, no one wants to […]
Question: Destination control statement is currently, “These items are controlled by the U.S. Government and authorized for export only to the country of ultimate destination for use by the ultimate consignee or end-user(s) herein identified. They may not be resold, transferred, or otherwise disposed of, to any other country or to any person other than […]
Question: I’m seeking some clarification on a few aspects of export compliance. I would be interested in knowing how the members identify routed export transactions within your company. Are these determined by the Incoterm used, or are there other methods to clearly define these transactions? What type of operational guidance to you give to Logistics […]
Question: Hi, I’m trying to find a good example of an export compliance screening questionnaire that can be used for companies or for foreign individuals. Can someone please share an example of one or point me in the right direction? I’d really appreciate it! Answer 1: Here is what we use for our audits. hope […]
Question: Hello, Members I am trying to understand what steps I need to take when a customer indicates “Military End Use” on the End User Form. I was given two conflicting pieces of information, and I would like to seek members’ help to sort this out. First thing first. Our Item is subject to EAR, […]
Question: I am currently working on developing an Export Control Matrix for my company to ensure ITAR compliance across various business segments, including Global Supply and Procurement, Engineering, and Business Development. We aim to align with DDTC guidelines and effectively manage our compliance risks. I have reviewed the DDTC ITAR Compliance Risk Matrix and created […]
Question: Can anyone provide information on where to sign up for updates on Export Control and Regulations? Looking for ways to stay updated. Thank you. Asked by: Sylvia Perez – sylvia_perez@comcast.net Answer 1: There are probably dozens of newsletters out there that one can subscribe to. I like the Bartlett Daily Bugle. Bartlett Publications – […]
