We have been seeing TAAs come from DDTC (State Dept.) that do not allow any subcontractors to have access to technical data or defense services under the TAA. This appears to be a recent change because older TAAs we have seen do not have this restriction. Instead, they permitted subcontractors of signatories to participate if […]
Has anyone heard any updates as to when new export regulations on Libya will finally go into effect?
Question: Does anyone require foreign subsidiaries to place the destination control statement, slightly modified to exclude the reference to being exported from the US, on their commercial invoices?
Question: Here is a hypothetical scenario: A joint venture company with 51% US ownership based in India sells product to a party in another country. The destination customer and country are not on any SDN, DPL, blocked party or embargoed list. The goods are sold on an FOB, Mumbai India basis. However, the goods are […]
We are implementing a new computer system that will allow us to automatically print all export shipping documents. Although we have always used a “Commercial Invoice” as our export invoice, we are being advised now that we should be using a “Proforma Invoice” as our export invoice because the commercial is not the invoice that […]
Question: 1. Do you have a routed export transaction on a FCA shipment if the foreign principal party in interest selects the carrier exporting the goods out of the US? 2. Is the USPPI responsible for cleared for export (i.e., statistical reporting and license determination, etc) on a shipment with incoterms FCA when the FPPI […]
Question: I would like to know how other companies screen for denied parties, embargoed countries, ect., for website order requests or for free downloadable software availability
Company A makes a product that is a “kit” with multiple pieces of > hardware and chemical solutions, cleaners, solvents. Company A > customers are now asking me for the schedule B number and ECCN number. > (it is not military, but could be dual use) My understanding is that > you can not classify […]
I am noticing a great deal of inconsistency in how BIS handles EAR violations. In some cases, I see voluntary disclosures closed by warning letters whereas in other cases, the same nature violation that was voluntarily disclosed is subject to a monetary penalty reduced by some percentage over the amount permitted by EAR (formerly $11,000 […]
In the agreements guidelines it states (p. 36) that a “letter of explanation” must be attached to license applications for hardware in furtherance of a TAA. This letter apparently is to contain the log of previous quantity/value/license #s to date that have shipped on the TAA. It also says to attach the full TAA and […]
My law firm has advised that if we have catalog product, and as a course of doing business, have all of the sales prints of our catalog products available through our web site, then it becomes public domain. In this approach, if we create a new product and put it in the catalog, even if […]
Hello, My question surrounds Hiring Foreign Nationals in China. We will need to secure export licenses from Commerce to share technology. Part of the license is for a tour when the Chinese nationals come to visit. So far I have identified the type of technology by ECCN. It also looks like I need a letter […]
