That title is a mouthful, pardon the expression, but it is a fact that the Office of the United States Trade Representative is accepting applications… Read More »USTR Provides Another Bite at the Section 301 Exclusion Extension Apple
George W. Thompson
Disruptions from supply chain and logistics backups have been all over the news lately. The problem is so serious that it’s even made it to the funny pages. Aside from these current systemic issues, every international sale poses logistics and supply chain concerns, since merchandise may get delayed, lost, or damaged in transit. The question then becomes which party,Read More »Do You Know Where Your Risk of Loss Begins?
A United States manufacturer of electronic test and measurement equipment and software mistakenly exported ITAR-controlled software under the EAR instead, resulting in a Consent Agreement and civil penalty of $6,600,000. Watch as George W. Thompson, International Trade Attorney discusses the consequences of this error and how it could have been avoided in ITAR or EAR?Read More »ITAR or EAR? Know Before You Export!
I learned a new word recently: “goat-rope.” The safe-for-work definition is a big, confusing mess. While it can be used to describe many different situations, I thought it was a perfect description for the ways in which the United States makes origin determinations for products imported from Canada and Mexico. Fortunately, help to make thingsRead More »CBP Proposes Streamlining Origin Rules for Imports from Canada and Mexico
It’s my long-held position that technology controls present the most challenging export compliance challenge. Last month’s consent agreement between the Directorate of Defense Trade Controls and Honeywell International illustrates my point quite well. As we’ll discuss, Honeywell fell into three of the most common traps for unauthorized exports of controlled information. Companies subject to the International TrafficRead More »DDTC Consent Agreement Highlights Technical Data Export Challenges
SAP, a German multinational software corporation with a significant U.S. presence, recently settled allegations that it violated OFAC and BIS regulations concerning exports of software, upgrades, and patches from the United States to Iran and Iranian companies. The settlement amounts totaled in excess of $6.4 million. Watch the video as George W. Thompson, International TradeRead More »Settlements for Exports of Controlled Encryption Software to Iran
Watch as international trade attorney George W. Thompson discusses the likely impacts on American international trade policies under the Biden administration. International Trade Policy Under the Biden Administration: What to Expect You can read original posting here > Thompson & Associates, PLLC
The Federal Trade Commission (FTC) has filed a Federal District Court complaint alleging that Chemence, Inc. committed unfair trade practices by claiming its merchandise, glue, is “Made in the U.S.A.” The FTC is charged with enforcement of statutes prohibiting the use of “unfair or deceptive acts or practices” in commerce. Its lawsuit seeks an injunction againstRead More »Manufacturer’s “Made in U.S.A.” Claim Challenged as False by FTC
Parenting can be such a chore. Minding wayward little ones, cleaning up after them, and getting hit with six-figure Treasury Department penalties for their misbehavior can offset the joy of beholding the smiles on their cherubic faces. Did I say Treasury Department penalties? Yes, they can arise when the parent is a U.S.-based company andRead More »More Apparent OFAC Violations Involving Foreign Subsidiary Companies
The Federal Trade Commission’s rules governing assertions that a product is “Made in the U.S.” can be confusing. As we’ve discussed on various occasions, that agency has strict standards on when claims of United States origin are permissible. I won’t repeat the Made In/Assembled In and qualified and unqualified claim distinctions here, except to note that theyRead More »“Made in USA” Rules — The Federal Trade Commission Wants to Hear from You