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 […]
Question: Would anyone be willing to share their knowledge & expertise on ENC? I have a Secure Services Gateway (5A002 Restricted) that I would like to export to the UAE. I am not the OEM; and, the end-user appears to have some form of foreign government ownership (i.e., approx. 60% of […]
Question: We obtain BIS export licenses for our encryption product sales to government end-users when we cannot use license expection “ENC”. One of the standard conditions on each license states that “Applicant must inform consignee of all license conditions”. Currently, our procedure is to send an email to the consignee informing them of […]
Question: I would like the membership for advise on the use of license exception RPL for 7A103 items. There is much debate within my company on this topic. My interpretation of this license exception when exporting from the U.S if the following with questions. 1) one-for-one replacement – export a part to replace a defective […]
Question: Scenerio: (U.S Company) ABC Inc sells a widget that is controlled under ECCN 3A001 to company 123. (U.S Company) ABC Inc then exports the widget to (Swedish) company 123 that resides in a country eligible for license exception GBS using the GBS license exception. (Swedish) company 123 takes the widget through an assembly process […]
Question: Scenerio: (U.S Company) ABC Inc sells a widget that is controlled under ECCN 3A001 to company 123. (U.S Company) ABC Inc then exports the widget to (Swedish) company 123 that resides in a country eligible for license exception GBS using the GBS license exception. (Swedish) company 123 takes the widget through an assembly process […]
Question: Does anyone have a best practice for lodging licenses? Do you lodge the licenses at the port of exit? If so, how do you transmit the license to customs and get a return signed acknowledgement? Or do you use carriers to lodge the license? ==========
Question: This question is posed for goods disassembled abroad where no export license would have been required under the DOC/BIS “roll-up” rule. At what point might a license be required when one of the constituent parts, that does require a license, gets harvested upon disassembly? Would a license be required to (re)import that part at […]
