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George W. Thompson

Cargo ship on its side in the ocean sinking

Do You Know Where Your Risk of Loss Begins?

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?
ITAR or EAR? Know Before You Export!

ITAR or EAR? Know Before You Export!

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!
USMCACBP.png

CBP Proposes Streamlining Origin Rules for Imports from Canada and Mexico

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
DDTC TECH DATA EXPORT

DDTC Consent Agreement Highlights Technical Data Export Challenges

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
night image of network of lights with buildings in the background Settlements Exports Controlled - Software Encryption

Settlements for Exports of Controlled Encryption Software to Iran

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

Manufacturer’s “Made in U.S.A.” Claim Challenged as False by FTC

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
OFAC

More Apparent OFAC Violations Involving Foreign Subsidiary Companies

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
Made In The USA

“Made in USA” Rules — The Federal Trade Commission Wants to Hear from You

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