Archive for the ‘BIS’ Category

AES Advice for STA Exports in the Shadow of the First STA Export

Monday, August 29th, 2011 by Holly Thorne

The first U.S. export made under License Exception STA took place in July and included products controlled under Category 6 (sensors and lasers), and arrived without incident to its European destination. This transaction would have previously required an export license from BIS if License Exception STA would not have been available.

License Exception STA authorizes exports of items in specific Export Control Classification Numbers (ECCNs) on the Commerce Control List without a license to the following 36 countries:

Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, South Korea, Spain, Sweden, Switzerland, Turkey, and the United Kingdom.

For certain ECCNs involving less sensitive items, software and technology, the following eight additional countries are eligible for license exception STA shipments:

Albania, Hong Kong, India, Israel, Malta, Singapore, South Africa, and Taiwan.

http://www.tradelawnews.com/; dnj@djacobsonlaw.com)

Sales Manager Fined $500,000 by BIS for One Export

Wednesday, July 13th, 2011 by Anna Barone

By John Black

Here is one for your in-house training of your sales staff.

The Bureau of Industry and Security (“BIS”) just released settlement documents announcing that Curtis Hickcox, a regional sales manager at PPG, agreed to a $500,000 penalty for exporting EAR99 epoxy paint without a license.  Hickcox also received a 15-year membership on the Denied Parties List and is required to take an export compliance training class.
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Export Control Reform Is Happening Now: BIS Adds License Exception STA to EAR

Wednesday, July 13th, 2011 by Anna Barone

By John Black

In the June 16, 2011 Federal Register, the Bureau of Industry and Security (BIS) created License Exception Strategic Trade Authorization (STA) in the Export Administration Regulations (EAR).  At the heart of STA is the determination that requirements for export/reexport licenses issued by BIS are not the best way to serve the interests of US export control policy.  The US Government apparently has determined that for the many of exports of many of the controlled items on the Commerce Control List (CCL), creating a License Exception STA information/paper trail between senders and recipients of controlled items serves US export control policy more effectively than requiring export or reexport licenses for those transactions.
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Available Customer Service/Export Compliance Position

Tuesday, July 5th, 2011 by Danielle McClellan
Basic Purpose

Responsible for the administration of customer service issues, customer communications and customer requests and orders on a daily basis. Maintain and ensure integrity of all customer data in the business systems, including customer property, orders and associated dollars.  Assure that all customer requests for quotes are properly managed in the PTS system. Responsible for maintaining and ensuring accurate backlog, orders, and market segmentation data.

Position Specification
Education/Experience

  • An Associates or Bachelors degree with a minimum of 5 years related industry work experience.
  • Solid understanding of military and commercial export compliance regulations.
  • Demonstrated ability to effectively and professionally communicate with all levels in the organization, vendors and customers.
  • Understanding of pricing models.
  • Proven negotiation skills.
  • Strong verbal and written communication skills.
  • Strong computer skills with working knowledge of MS Office and Access.
  • Proven team-work capabilities and experience.
Additional Requirements

  • Understanding of the Fourth Shift or Syteline ERP system.
  • Able to handle and resolve customer complaints and problems and escalate when required.
  • Willing and able to develop long-term relationships internally and externally.
  • Attention to detail.
Functional Scope

The Customer Service Representative provides support to both the internal and external customers of the company.  This position plays an active role in the maintenance and management of the various business systems. Success in this role will require a proactive approach and the ability to create and implement process improvements to ensure that the systems and processes are as robust as possible to provide superior service to the customers.

Duties and Responsibilities

  • Responsible for the accurate and timely management of all sales order activity.
  • Ensure all sales data is accurate and complete in order to maintain order, market and backlog reporting integrity including schedule and associated dollars.
  • Responsible for raising export compliance concerns to the DECA or DECA backup when required.
  • Serves as a central point of contact for customer inquiries. Provides customers with updated order and delivery status.
  • Responsible for inputting data (RFQs, pricing, status, etc) into the PTS (Proposal Tracking System) and ensuring that all data is accurate and complete and up to date.
  • Provides engineering with request for quote information required to initiate estimating process.
  • Performs contract review and order acceptance process. Controls and maintains master contracts/ purchase order files.
  • Assists with the configuration control process.
  • Performs the EDI transaction conversion to the business system. Tracks changes in delivery dates, prices and handles terminations.
  • Maintains customer information in the various business systems.
  • Responsible for disseminating Terms and Conditions, special shipping instructions, configuration changes and quality requirements throughout the organization.
  • Assists accounting with invoicing and collection issues.
  • Review Customer Scorecards.
  • Perform other duties as required by the business and as instructed by supervisor.

Essential Functions of Position

Interpersonal Skills

  • Must be able to communicate clearly and effectively with all levels of personnel within the organization and the customer.
  • Must be able to communicate orally and/or in writing as to work requirements, work in progress, and/or work completion
  • Must be able to follow complex instructions and/or directions. May require ability to decide on a course/sequence of action

Schedule and Planning

  • Must be able to schedule and organize time effectively to satisfactorily complete assigned tasks and functions.

Physical Effort

  • Minimal physical effort
  • May be required to travel occasionally to customer premises or corporate office.
  • Operate personal computer.

Working Conditions

  • Primarily work in office areas with exposure to shop floor.
  • Generally responsible for the safety and clean up of own work area.

Disclaimer

  • The above information on this job description has been designed to indicate the general nature and level of work performed by employees within this classification. It is not designed to contain or be interpreted as a comprehensive inventory of all duties, responsibility and qualification required of employees assigned to this job.

Contact Pamela R. Daly regarding this position at:

Barnes Aerospace

169 Kennedy Rd

Windsor, CT 06095

P: 860-687-5270

F: 401-228-0823

pdaly@barnesaero.com

$100,000 Penalty for 14 Violations Committed by Meritor of Troy

Tuesday, May 3rd, 2011 by Anna Barone

The Commerce Department’s Bureau of Industry and Security (BIS) has recently announced that Meritor of Troy, MI has committed 14 violations of the Export Administration Regulations. They have agreed to pay a $100,000 civil fine to settle allegations. The company recognized their own offenses, disclosed the violations and fully cooperated with the investigation of the Office of Export Enforcement.

Between August 2005 and November 2006 there were two instances in which Meritor shipped products, that were controlled for national security reasons, to China and France. Also, between December 2005 and May 2006 there were twelve instances in which the company exported technical data, that was controlled for national security reasons, to Italy, India, China, Mexico, South Korea and Brazil.

Meritor is a global leader in providing innovative drivetrain mobility and braking solutions for original equipment manufacturers of trucks, trailers and specialty vehicles, as well as the related aftermarkets in the transportation and industrial sectors.  They celebrated a centennial anniversary in 2009.

More Information Available:

http://www.bis.doc.gov/news/2011/bis_press03222011.htm

Export Compliance Training? Important? You betcha!

Monday, April 4th, 2011 by John Black

The risks of fines of hundreds of thousands — or even millions — of dollars for violations make export compliance important.  The complicated, arcane, and voluminous regulations that impose incredible burdens on your day-to-day business activities make export compliance difficult.  A thorough and effective multi-level company training program makes a reasonable level of export compliance achievable.

A company needs three levels of training (more…)

$1,458 Installment Payment Plan for Export $1,458 Installment Payment Plan for Export Violations

Friday, February 18th, 2011 by Danielle McClellan

After being convicted of 14 violations of the EAR, Yuri I. Montgomery a/k/a Yuri Malinkovski has been charged with a civil penalty of $340,000 of which $322,500 has been suspended. The remaining $17,500 will be paid by Yuri in 12 installments of $1,458. Now this may seem like Yuri got off easy, but he also received the death penalty. For a period of 30 years Yuri Montgomery is a “Denied Person” so no one can act for him, on behalf of him, represent him, even his agents and employees cannot participate in any activities subject to the Regulations.

More information available at: http://edocket.access.gpo.gov/2010/2010-32563.htm

Equal Opportunity

Friday, February 18th, 2011 by Danielle McClellan

Bruce Leeds, Esq. has been named President of the “Women in International Trade-Los Angeles” for 2011.  Now you may be asking if this is a typo or some sort of oxymoron, well it’s not. The organization actually represents both men and women, but I have to wonder why they don’t just call themselves the “Men and Women in International Trade.”

Bruce says: “Although it may seem unusual that a male will be President of WIT-LA, it emphasized the point that the organization represents all the people involved in export-import trade and regulations. I look forward to working with a very talented board of directors of both genders and many different backgrounds, to create valuable programs that serve the trade community.”

Website: http://www.wit-la.org/index.asp

New Certification Requirement in Immigration I-129 Form Begins February 20, 2011

Friday, February 18th, 2011 by John Black

As many of you know a new Form I-129 requirement forces companies requesting a work visa to certify that they do not have any technology that requires an export license for the potential employee, or that they either have an export license or procedures to prevent access to export license-required technology. (more…)

BIS Announces New Validate End-User (VEU)

Friday, February 18th, 2011 by Danielle McClellan

Effective January 18, 2011 BIS added CSMC Technologies Corporation to the validated end-users program in the People’s Republic of China. In a nutshell the program allows certain items to be exported, reexported, or transferred (in-country) to approved companies and in this case 3 CSMC facilities.

BIS has also revised the validated end-user authorization for Advanced Micro Devices China, Inc. by updating the list of the company’s approved buildings and the descriptions of items that are eligible for export, reexport, or in-country transfer to AMD.