Question: I realize this isn’t the forum for “official legal advice”, however, a second or third opinion on which, if any, Part 127 or other violations may have occurred in the following scenario would be much appreciated:A fixed amount of specific USML commodities (hardware only) listed in Blocks 9-13 were/are still listed on a DSP-05, […]
Question: A defense service is furnishing assistance or technical data to a foreign person. So, of course, this means that assisting or furnishing technical data to a US person is not a defense service. But what about foreign persons furnishing assistance or technical data to another foreign person?Once the lawful export has been made via […]
Question: We utilize DSP-5 to transmit technology to our foreign subsidiaries and their customers. Our foreign subsidiary is looking at hiring an IT firm to assist them, that would have access to their system. While the intent is not to provide them and controlled technology, they would technically have access to their network. Should the […]
Question: I fully understand that ITAR hardware and technical data do NOT need to be involved for a US person to perform a defense service.What I want validation on is that if the US PERSON is performing a service related to what would be an EAR 600 series item, that indeed is not a “defense […]
Question: How can i study for the ITAR and/or CUSECO examinations? Answer 1: When I obtained my CUSECO certification, it was through ITC and I completed 4 courses in preparation for the exam. The courses were focused on exporting, and the regulations. The courses were online and structured with readings, interaction with others taking the […]
Question: For organizations using digital visitor management systems or paper sign-in sheets, do you require visitors to present a government-issued photo ID on every visit, including both returning and first-time guests? Looking to understand common practices and consistency across different approaches. Answer 1: We do require them to present a photo ID. Since we have […]
Question: Hello,for a little more than a year, our company has involved an individual (U.S. citizen) to help facilitate the exporting of our products, many of which are listed on the USML, to parts of the EU and elsewhere. It is evident the actions undertaken by this individual, on our firms’ behalf, constitute “brokering activities”. […]
Question: What measures should be taken to prevent noncompliance on patent application for product that could be developed for potential ITAR use? Answer 1: I may be a little out of date, but generally to be considered ITAR, a product would have to be developed specifically for military use (not withstanding potential dual use possibilities). […]
Question: I am looking into hiring a Foreign Person for some consulting work outside of the U.S. They would not be a direct hire, but instead would be hired as a contractor through a staffing agency in their home country. We would need to obtain a DSP-5 to share ITAR-controlled tech data and my question […]
Question: The company has purchased a server (hardware) which will be configured in the U.S. with customized software that is ITAR-controlled prior to shipment to the United Kingdom. The ITAR-controlled software will be exported to the UK foreign entity under an ITAR exemption. Generally speaking, EEI filings are not required for intangible exports (i.e., software). […]
Question: I have a potential non-compliance risk related to a temporary export under the ITAR. Product under the license was to have shipped to a specific country yet somehow ended up in a completely different country where the risk is separate potential violation of EU export requirements because exporting the product from the EU may […]
Question: We are in the final implementation of our Canadian Controlled Goods Program registration that will enable us to receive ITAR technology in our Canadian facility. One area of concern is with visitors. I think it comes from the idea that the CCGP requires an individual access as well as the company’s access program. In […]
