EAR

The New Foreign-Direct Product Rule for Third-Country Exports to Russia

by George W. Thompson
June 1, 2022June 1, 2022

Sanctions imposed on Russia by the BIS The February 24 sanctions imposed on Russia by the BIS have put in place a vastly expanded definition of the foreign-direct product rule,Read More »

The Unverified List: What it Means to Exporters, Re Exporters, and In-Country Transferors

by George W. Thompson
April 26, 2022May 24, 2022

The Unverified List The Commerce Department’s listing of foreign companies subject to restrictions on all items included in the Export Administration Regulations, has received increased attention as a result ofRead More »

Sentenced to Federal Prison for Attempting to Smuggle Items Out of the U.S.

Sentenced to Federal Prison – Smuggle Items Attempt Out of the U.S. Without the Required Export License

by GTC Repost
April 6, 2022April 6, 2022

Owner of Maryland Export Business Sentenced to Federal Prison for Attempting to Smuggle Items Out of the U.S. Without the Required Export License Baltimore, Maryland – U.S. District JudgeRead More »

The Foreign-Direct Product Rule

by George W. Thompson
March 29, 2022May 20, 2022

The Foreign-Direct Product Rule is a provision of the Export Administration Regulations The following transcript from George W. Thompson, explains the criteria under which some foreign products are subject toRead More »

Export Controls Aircraft Private and Public

Commercial and Private Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls

by GTC Repost
March 22, 2022March 30, 2022

The U.S. Commerce Department, through its Bureau of Industry and Security (BIS), publicly identified commercial and private aircraft that have flown into Russia in apparent violation of the Export AdministrationRead More »

U.S. Department of Commerce Implements New Export Controls to Combat Malicious Cyber Activities

by GTC Repost
March 22, 2022March 22, 2022

Key Points On March 7, 2022, new U.S. export controls applicable to “cybersecurity items” took effect based on an interim final rule published by BIS on October 21, 2021 (the “CyberRead More »

ITAR or EAR? Know Before You Export!

by George W. Thompson
September 20, 2021September 19, 2022

ITAR or EAR 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 civilRead More »

DDTC Consent Agreement Highlights Technical Data Export Challenges

by George W. Thompson
July 20, 2021May 10, 2022

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 quiteRead More »

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

by George W. Thompson
May 28, 2021May 26, 2022

OFAC and BIS regulations 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,Read More »

Military Network Technician Inspecting Server

An EAR-evolution? What Commerce’s military intelligence end-user rule may foretell

by GTC Repost
May 6, 2021May 10, 2022

Although historically less attention-grabbing than sanctions, US export controls have been progressively newsworthy in recent years–starting with the Trump administration’s headlining restrictions aimed at Huawei, initiated in May 2019. MoreRead More »

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