QUESTION: Is it a common practice to share the actual copy of an export license with a consignee listed on the license? What reason could be used not to share the license and use a company letter stating the conditions and requesting an acknowledgement? ****************** Answers: Normally YES. If there are specific provisos that pertain […]
Question:  Could the membership please comment on what value they assign for Technical Data on a DSP-5? We have a disagreement in our office over how to determine the value for technical data and whether a Tech Data license needs to be decremented when data is provided to a foreign party. It would be helpful […]
Question: Say I export my product (EAR99) to Germany. At this point I file AES with NLR. A couple of months go by and learn that that product is going to a sanctioned country where an export license is required. If I knew that the product was going to be on-forwarded to a sanction country […]
Question: We (US Company) recently acquired a Swiss company who has active export licenses under their name, we want to dissolve that legal entity name but want to see if those licenses can be assigned to the new parent (US) company name. Does anyone know where to find information about it? ************** ANSWERS: I assume […]
Question: I’m new to the Export license issue as I have been primarily involved with Imports in the past. I’m being advised that if a Department of State export license was granted for one of our business units, it is acceptable for another business unit to export the good, file the export declaration via AES […]
Question: For the 117 or so companies who BIS says are making use of License Exception STA: how long do you keep or plan to keep your consignee statements signed by the end user before requesting new ones? I didn’t see anything in 740.20 about how long they are valid.
Question: We sold a product (an electronic measurement instrument) to a customer in France a few years ago. It was, and still is, classified under an ECCN that is controlled under NS2 and CB2, therefore we exported without a license. We don’t have ownership or control of the product. Our original export contained the […]
Question: We obtained a license from OFAC to affect a payment to an Iranian. The license application listed the banks that potentially would be involved, including the recipient’s bank in the United Arab Emirates. The license took a year to get approved; […]
Question: Suddenly I have a fair amount of items classified as 5A002 to export from the USA. These are purchased items – we don’t make them and this type of product is not our core business so I’m not fully familiar with requirements. These items are NS1 controlled and need a license for US […]
QUESTION: Is there any way to get a blanket EAR license for a product to a certain customer, or does the specific unit & serial number have to be known prior to obtaining an EAR license? For example, if I have one specific product (several different model numbers) all controlled for the same reasons […]
Is there any way to get a blanket EAR license for a product to a certain customer, or does the specific unit & serial number have to be known prior to obtaining an EAR license? For example, if I have one specific product (several different model numbers) all controlled for the same reasons can […]
Question: We have a short list of eleven raw materials controlled for export under the EAR. Of these materials, a few are now inactive/no longer in use and only 2 of the 11 have current inventory levels. When reviewing a foreign national for potential hire against the controlled materials and export controls […]