Tag Archives: Export Controls

Export Licenses Are Now C.O.D. – Department Of State Modifies ITAR Registration Fee Structure To Increase Fees And Provide For More Consistent Revenue Stream

Effective September 25, 2008, the U.S. Department of State, Directorate of Defense Trade Controls ("DDTC") – the agency that administers export control regulations under the International Traffic in Arms Regulations ("ITAR") (22 C.F.R. Parts 120-130) – issued a final rule modifying the ITAR registration procedures and increasing the registration fees based on a company’s need … Continue Reading

New DOD Rule Imposes Contractual Requirement For Contractors To Comply With U.S. Export Laws

Effective July 21, 2008, the U.S. Department of Defense ("DOD") issued an interim rule with a request for comments that creates a contractual obligation for all DOD contractors to comply with U.S. export control laws.  See 73 Federal Register 42274.  While, technically, the interim rule does not impose any new requirement on U.S. businesses, because … Continue Reading

Comments On Proposed CFIUS Rules Range From Cautious Praise To Outright Criticism

As discussed in a prior posting on this blog, the U.S. Department of the Treasury published on April 21, 2008 proposed rules designed to strengthen the process by which the Committee on Foreign Investment in the United States ("CFIUS") reviews and approves certain business transactions involving foreign investment. The proposed rules were issued under the … Continue Reading

Treasury Proposes New Rules For Reviewing Foreign Investment In U.S. Companies

On April 21, 2008, the U.S. Department of the Treasury ("Treasury") proposed new rules relating to the procedures that the Committee on Foreign Investment in the United States (“CFIUS”) should use in reviewing (and potentially halting) foreign investments in U.S. companies based on a potential impact on national security.  See 79 Fed. Reg. 21861.  While … Continue Reading

Pending Legislation Would Expand Extraterritorial Prohibition On Doing Business With Iran, Even For Foreign Companies; U.S. Companies With Foreign Subsidiaries Should Be Warned

Background on U.S. Trade Regulations and Export Laws Many people say that U.S. foreign policy is a mess. While this point is clearly debatable, it seems clear that the U.S. laws, regulations, and executive orders attempting to implement U.S. foreign policy certainly are a mess. Nowhere is this "mess" more clearly evident in the U.S. … Continue Reading

Turning the Screws on Export Controls

An effective export control policy – one that addresses all of the applicable export regimes, effectively trains company personnel with respect to the companies’ obligations, and monitors adherence to the requirements set forth in the policy – is an essential element of a comprehensive corporate compliance program. Although the need for such policies may appear to … Continue Reading

A Primer On U.S. Export Controls

Exporting products and technology from the United States is a privilege, not a right.    U.S. export laws have a broad reach — they govern U.S. products and technology, foreign products and technology that reside in the U.S., and foreign products and technology that has any U.S. content, even if overseas. Classify your products — "defense … Continue Reading

Export Enforcement

On June 20, 2007, the U.S. Department of Justice announced the appointment of Steven W. Pelak as the first-ever National Export Control Coordinator. Mr. Pelak’s job is "to improve the investigation and prosecution of illegal exports of U.S. arms and sensitive technology." The creation of this position follows on a number of recent high profile … Continue Reading

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