The ECTI website now offers The Searchable Commerce Control List (CCL) for your convenience (and to keep the frustration of endless searching at bay). This new version is based off the e-CFR, and in addition to the CCL itself, the document also includes an alphabetical index, as well as broken down individual categories. The full CCL may be downloaded to your desktop here and will be updated monthly.
Archive for the ‘CCL’ Category
ECTI Website Now Offers Searchable CCL
Tuesday, November 1st, 2011 by Holly ThorneExport Control Reform Is Happening Now: BIS Adds License Exception STA to EAR
Wednesday, July 13th, 2011 by Anna BaroneBy 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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Export Compliance Training? Important? You betcha!
Monday, April 4th, 2011 by John BlackThe 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 McClellanAfter 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 McClellanBruce 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
BIS Announces New Validate End-User (VEU)
Friday, February 18th, 2011 by Danielle McClellanEffective 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.
Don’t Do This: PPG’s License Application Denied and It Went Ahead Anyway
Friday, February 18th, 2011 by John BlackWas I dreaming when I read various export control pundits talking about the significance of the PPG enforcement case (reported above) because the US went after a company in China or because there was this indirect issue or that indirect issue? Sorry, this is not new. The new importance and “sweeping significance” of this is way over-rated. It appears some experts are attempting to distort the importance to make it a broader, scary issue. The issue is they got a license denied and shipped anyway. That has always been at the top of my personal list of violations not to commit.
Shipping after a license is denied is willful and knowing and intentional and criminal, and, by the way, stupid. Not only did they know a license was required, they knew the USG would deny the license. People could have gone to jail and companies could have been added to the denial list. Not a mistake or accident here but intentionally violating the regulations. Add that to nuclear facility, entity list, China and Pakistan, and you have a big ole stew of aggravating factors
Perhaps I should apologize for saying the violation was stupid. My mother always says it is rude to say “stupid.” OK, the violation demonstrates a lack of sound judgment and thought and illustrated behavior based greed. I just assumed that everybody knows that if BIS denies your license application, there is a good chance BIS will watch your company closely because BIS suspects your company will ship anyway. You know why BIS does that? Because idiotic (my mother doesn’t read this stuff) companies ship anyway when their license is denied. (more…)
BIS Proposes New License Exception
Wednesday, January 12th, 2011 by Danielle McClellanBIS is proposing to add a new license exception which would allow exports, reexports and transfers of specific items to destinations of little risk without having to obtain a license. Now this doesn’t mean that the export is free and clear of any “time consuming” work for exporters, notification to BIS, destination control statements and consignee statements will be required for this exception. (more…)
BIS’ Kevin Wolfe Begins Free Weekly Teleconferences
Wednesday, January 12th, 2011 by Danielle McClellanBeginning December 22, 2010 Assistant Secretary for Export Administration, Kevin Wolfe, will be providing free teleconferences every Wednesday through February 2, 2011 from 2:00 pm – 4:00pm EST to discuss Commerce’s proposed rules related to the Administration’s effort to reform the export control system.
The free conferences are limited to 100 people per session; to participate you must dial in at 866-917-2713; participant code: 4136642. You may also submit questions in advance of the training to be answered during the teleconference, submit your questions to oesdseminar@bis.doc.gov
Information available at: http://www.bis.doc.gov/news/2010/teleconference_opportunity_wolf.htm
New Work Visa Application Requirement Reminds Applicant Company of Export Control Requirements
Tuesday, January 11th, 2011 by Danielle McClellanAs of November 23, 2010 the US Citizenship and Immigration Services (USCIS) will now require all new employees of H-1B (professional), L-1 (intracompany transferee), and O-1 (extraordinary ability) non-immigrant foreign national workers to confirm that they have reviewed the EAR and the ITAR. They will also have to confirm that a license is not required from the Department of Commerce or the Department of State to release technology or technical data to them, meaning they must have some understanding of the regulations. (more…)
