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export controls

BIS Sanctions Export to Russia

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

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, which will pose significant compliance challenges.   In the following transcript George Thompson details which products are affected by the new rule and how itRead More »The New Foreign-Direct Product Rule for Third-Country Exports to Russia
USDOC

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

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 of the recent addition of 33 Chinese industrial and technology companies to the list. The following transcript from George Thompson's video, explains what the Unverified ListRead More »The Unverified List: What it Means to Exporters, Re Exporters, and In-Country Transferors
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

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 Judge George L. Russell, III today sentenced Jorge Orencel, age 65, of Silver Spring, Maryland, to six months in federal prison, followed by one year ofRead More »Sentenced to Federal Prison – Smuggle Items Attempt Out of the U.S. Without the Required Export License
The Foreign-Direct Product Rule

The Foreign-Direct Product Rule

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 to the EAR and are thereby within the scope of export controls even if they have no physical U.S. origin content. Hello again, this is GeorgeRead More »The Foreign-Direct Product Rule
Export Controls Aircraft Private and Public

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

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 Administration Regulations (EAR).  In so doing, BIS is notifying the public that providing any form of service to these aircraft requires authorization. Absent such authorization, anyRead More »Commercial and Private Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls
New Export Controls to Combat Malicious Cyber Activities

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

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 “Cyber Rule”). The controls under the Cyber Rule are complex because they restrict exports intended for malicious cyber activities and to certain countries and governments, butRead More »U.S. Department of Commerce Implements New Export Controls to Combat Malicious Cyber Activities
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