Question: We have a short list of eleven raw materials controlled for export under the EAR. Of these materials, a few are now inactive/no longer in use and only 2 of the 11 have current inventory levels. When reviewing a foreign national for potential hire against the controlled materials and export controls […]
Question: Would anyone be willing to share their knowledge & expertise on ENC? I have a Secure Services Gateway (5A002 Restricted) that I would like to export to the UAE. I am not the OEM; and, the end-user appears to have some form of foreign government ownership (i.e., approx. 60% of […]
Question: We obtain BIS export licenses for our encryption product sales to government end-users when we cannot use license expection “ENC”. One of the standard conditions on each license states that “Applicant must inform consignee of all license conditions”. Currently, our procedure is to send an email to the consignee informing them of […]
Question: I would like the membership for advise on the use of license exception RPL for 7A103 items. There is much debate within my company on this topic. My interpretation of this license exception when exporting from the U.S if the following with questions. 1) one-for-one replacement – export a part to replace a defective […]
Question: Scenerio: (U.S Company) ABC Inc sells a widget that is controlled under ECCN 3A001 to company 123. (U.S Company) ABC Inc then exports the widget to (Swedish) company 123 that resides in a country eligible for license exception GBS using the GBS license exception. (Swedish) company 123 takes the widget through an assembly process […]
Question: Scenerio: (U.S Company) ABC Inc sells a widget that is controlled under ECCN 3A001 to company 123. (U.S Company) ABC Inc then exports the widget to (Swedish) company 123 that resides in a country eligible for license exception GBS using the GBS license exception. (Swedish) company 123 takes the widget through an assembly process […]
Question: Does anyone have a best practice for lodging licenses? Do you lodge the licenses at the port of exit? If so, how do you transmit the license to customs and get a return signed acknowledgement? Or do you use carriers to lodge the license? ==========
Question: This question is posed for goods disassembled abroad where no export license would have been required under the DOC/BIS “roll-up” rule. At what point might a license be required when one of the constituent parts, that does require a license, gets harvested upon disassembly? Would a license be required to (re)import that part at […]
Question: Does anyone have a best practice for lodging licenses? Do you lodge the licenses at the port of exit? If so, how do you transmit the license to customs and get a return signed acknowledgement? Or do you use carriers to lodge the license? ***********
Question:We have a licensable valve that will be export to a shipyard in Asia to be installed in a module that will then be assembled on a ship for deep water oil recovery. We do not have any control of the facility at this shipyard. The company that will take possession of the export is […]
Question: I am confused about who is allowed to actually export against a DSP-5 license. Is it only the applicant? Or is it anyone listed…the applicant (block 5), seller (block 19), source (block 17), US Consignor (block 21)??? Are all of these parties allowed to export (and act as USPPI for EEI)? Why would […]
I would like to get some feed-back from members that have Deemed ExportLicensed individuals in their facilities.I am wanting to draft a memo to employees in the same location,reporting structure, associates, etc.. – that may have daily contact with thelicensed individual, notifying these employees that no “technicalinformation, drawings, designs, etc.. Can be shared with the […]
