QUESTION: Where in the EAR does it indicate who can view a BIS export license? Can a paper copy of the license accompany the shipment if the actual license gives no indication of confidentiality? ========== Answers: Why would anyone need to send a copy of the export license with the shipment? I believe those records […]
QUESTION: Our company exports goods that fall under EAR-99. The Export Compliance Guidelines in the BIS website recommends that a Management commitment statement be signed by the President or CEO of the company to be distributed to all employees on an annual basis. I forwarded the example statement (below) to the head of our legal […]
QUESTION: We are a foreign entity located in Mexico and manufacture EAR600 as well as ITAR goods, the US customer does have a BIS license as well as DDTC licenses in place and we are listed on these licenses. My question is: if the foreign Mexican entity sends tech. data to a US supplier for further […]
QUESTION: We manufacture and export EAR99 food products. We are re-visiting our new customer application form to ensure we are capturing the necessary areas of risk for denied parties screening (I’m using this term broadly for the screening of 100+ govt lists). What are some best practices for creating a new export customer application form […]
QUESTION: My company manufactures highly complex electronic manufacturing production equipment. The completed system is classified as EAR99. However, there are licensable component parts in the system which, when shipped as spare parts or replacement parts, require a Commerce department license to certain controlled destinations such as China. For various logistics reasons, our crating company would […]
QUESTION: The General Export License for ZTE Corp expires on 2-27-17, I have not seen anything on what BIS plans to do with them. Will they extend the license or remove them from the Entity List? ========== Answers: The Temporary General Export License for ZTE has been extended to now expire on March 29. 2017. […]
QUESTION: For the purposes of complying with the EAR and ITAR, is there a distinction between a Letter of assurance and an End-user statement, are such forms required by regulation. Does BIS or DDTC have specific formats to follow? ======================= ANSWER: End-User Statements (EUS) I submit to DDTC come primarily from our customers. I […]
QUESTION: How many USPPI’s obtain documentation of EAR Sec. 758.3(b) assumption of licensing authority from the FPPI in routed transactions? ========== We have wording on our end use / end user forms stating the FPPI is responsible for any license determination. With that said, almost 99% of my exports are EXW and routed transactions. I […]
QUESTION: Our company had an inquiry for purchase of a license for our EAR99 software from an organization on the SDN due to EO13685. The only option I see to complete the sale would be to apply for a specific license since none of the general licenses apply to this situation. Two questions: Does OFAC […]
QUESTION: I read the destination control statement on the invoice from 15 CFR Sec. 758.6 to in effect/by implication require that the ultimate consignee be identified (name, address, country) on the invoice (unless EAR99 items). Has the membership faced any pushback/requests from foreign customers (e.g. re-sellers) not to include (to remove) this ultimate consignee information […]
QUESTION: We have always handled only ITAR, now some items have moved to EAR. We import parts from a foreign supplier, some were defective and need to be replaced. License exception RPL does not seem to fit this circumstance. Any guidance? ************* Answers: You may want to also see if Return of Foreign Origin Items […]
QUESTION: Please provide guidance on the steps involved when a company is contracted by Dept of Navy to manufacture a product to be used by the government armed forces? Our product is more than likely, EAR99, because it does not have sensitive military capabilities. It is a non-electrical product, similar to a typical nut, bolt […]
