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ITAR

ITAR VIOLATION

First time DOJ has charged hacking as a violation of ITAR

In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“ DOJ ” or the “Department”) corporate enforcement. Of particular note, and which has been largely unnoticed, Carlin highlighted the Department’s heightened focus on sanctions and exportRead More »First time DOJ has charged hacking as a violation of ITAR
ITAR or EAR? Know Before You Export!

ITAR or EAR? Know Before You Export!

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 civil penalty of $6,600,000. In the following transcript George W. Thompson, International Trade Attorney discusses the consequences of this error and how it could have beenRead More »ITAR or EAR? Know Before You Export!
USA ITAR

ITAR Brokering Activities Demystified

Part 129 of the International Traffic in Arms Regulations (“ITAR”) requires certain persons engaged in “brokering activities” to register with and pay a fee to, the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”). ITAR Part 129.2 broadly defines “broker” as any person engaging in “brokering activities” (discussed in greater detail below) fittingRead More »ITAR Brokering Activities Demystified
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
Export Controls: Five Charged in Scheme to Export thermal imaging devices subject to ITAR Five Charged in Scheme to Export

Five Charged in Scheme to Export Thermal Imaging Scopes and Night Vision Goggles to Russia, in Violation of Arms Export Control Act

A federal grand jury in Los Angeles unsealed an indictment Thursday that accuses five defendants of conspiring to unlawfully export defense articles to Russia. Specifically, the defendants allegedly exported thermal imaging riflescopes and night-vision goggles without a license, in violation of the Arms Export Control Act. According to court documents, Elena Shifrin, 59, of Mundelein,Read More »Five Charged in Scheme to Export Thermal Imaging Scopes and Night Vision Goggles to Russia, in Violation of Arms Export Control Act
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

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, and patches from the United States to Iran and Iranian companies.  The settlement amounts totaled in excess of $6.4 million.   In the following transcriptRead More »Settlements for Exports of Controlled Encryption Software to Iran

Is Your Company Capitalizing on Free Trade Agreements (FTAs)?

The primary purpose of free trade agreements (FTAs) is to lower or remove tariff barriers that hamper the active trade of goods and services between countries and to protect intellectual property rights. The U.S. alone has more than 12 FTAs, and there are more than 400 regional trade agreements worldwide; even so, it appears that many companies fail to leverage this opportunity to open up foreign markets to their products. Based onRead More »Is Your Company Capitalizing on Free Trade Agreements (FTAs)?

The Meaning of Export Controls-Part2

Export Controls: Denied Parties  With concerns about the unauthorized and/or inappropriate transfer of technology, products, and information to individuals or entities within or beyond US borders, the US Government established laws and regulations, known as export controls, to restrict such transfer. The government regulates the export of sensitive information, physical equipment, and software and technology to promote foreign policy objectives and promoteRead More »The Meaning of Export Controls-Part2

What is ITAR?

What is ITAR compliance? The International Traffic in Arms Regulations (ITAR) are, as the title indicates, rules governing trade in munitions. While that summary is accurate, it leaves many open questions. What are “munitions”? How is trade in munitions defined? Who is engaged in such trade, what authorizations are United States exporters and foreign re-sellersRead More »What is ITAR?