Question: Hello, I have a question to the community regarding foreign integrators and End Use/End User definition. In reviewing the EAR definition of “end-user” and previous ICPA database answers, it was not definitive if it would consider the foreign integrator as an “end-user” in below scenario of Item A? Scenario: Item A shipped from US […]
Question: I am looking for guidance on how firms that develop ,share ,and store software “subject to the EAR” maintain compliance, particularly in cloud applications. The EAR 734. 18 (5) exclusion provides for electronic transmission of controlled tech and software that is not considered an export if it meets the “end to end” encryption standards […]
QUESTION: How would someone report another company’s export violation? Example: a logistics company is asked to ship something to UAE but mark it as final destination Syria, so it is clear that the intention is the evade the sanctions on Syria. How would they report that to OFAC? ======================================================== Contact your regional OEE (Office of […]
QUESTION: Interested in what specific KPI reporting industry measures for their exports. Things like: How many exports? Where are our exports going? How many shipments require a license? How quickly do we receive approval of licenses? How many exports require an EEI declaration? What part numbers are we exporting frequently? Any suggestions would be […]
Your Social Security Statement QUESTION: We are a large automotive company with mostly EAR99 goods. We are proposing to have a basic online 15-20min export compliance awareness training for all employees. We are getting some pushback on requiring all employees to take this course. Are other companies requiring awareness training for all employees? If […]
QUESTION: Looking for guidance from the membership. My company is sending an ex-pat to Germany and their personal items need to ship. Total value of the shipment is about $350 USD. What is the best way to get these items past German customs? Items are keyboards, office supplies and disinfectants. ========== Answer Each customs agency […]
QUESTION: My company is a distributor, with a majority of sales activities occurring to resellers. Sometimes in the course of a domestic sale, the reseller would prefer that we ship their purchased goods directly to their foreign customer. Further, we generally have very competitive rates with our carriers, better rates than most of our domestic buyers may […]
QUESTION: I’ve been asked to put together US export compliance training for our foreign subsidiaries. These are a mix of companies that are either wholly owned by the US parent, or majority owned by the US parent. All companies both manufacture their own products in country for sale to their own customers and also […]
QUESTION: Does §30.37(a) supersede §30.36? Can we use exemption §30.36 when exporting NEW vehicles to Canada? The note under §30.37(a) Miscellaneous exemptions state the following: Note: this exemption does not apply to the export of vehicles. The export information for vehicles must be filed in AES regardless of value or country of destination. It is clear exemption §30.37(a) cannot be used for vehicles even if they are being exported to […]
QUESTION: Companies that manufacture ITAR products in a maquiladora/IMMEX – anyone know how many do this, is it common? How do they set it up, avoid risks? **************** Answers: You will need to obtain a Manufacturing License Agreement from the DDTC. See 120.21 of the ITAR ***************From my understanding based on past experiences, rare or […]
QUESTION: I plan on shipping an item enumerated in the CCL to a Military End-User (Coast Guard- not in China, Russia, or Venezuela). Based on the reasons for control for the ECCN and the country of ultimate destination, a license would not be required. However, because of the update to the definitions of Military End-User/Users, […]
QUESTION: We have technical data documents that are export-controlled and are currently stored on local servers. Is it permissible (after any appropriate licensing) to use a cloud storage solution based outside the U.S.? **************** Answers: While in the past, storing technical data outside the US was considered an export by both Commerce (EAR) and State […]
