QUESTION: I found out that equipment that my product is used in as an “attachment” is on the CCL Alphabetical Control List and has an ECCN number but my product is not on the Alphabetical Control List. While I do not see the name of my product on the Alphabetical Control List would it be […]
QUESTION: We have historically dealt primarily with ITAR controlled hardware. When our foreign parent needed to scrap damaged hardware no longer useable, we submitted a General Correspondence (GC) on their behalf to allow them to scrap the material. We now have many situations where the hardware has transitioned to 600 series ECCN from CAT […]
QUESTION: Does an employee in a U.S. corporation who holds dual citizenship (U.S. and Israel) need a license to work with ITAR-controlled products? Or, is this employee is a citizen regardless and NLR? ************** Answers: Once a person becomes a US citizen, no licenses are required. However It is not the same for permanent residents. […]
QUESTION: I am working with senior leaders in our company to establish an HR policy on hiring of foreign persons. The company has recently consolidated a number of separate entities under a single company here in the US. We are incorporated in the US, but foreign owned and ITAR registered as a manufacturer / exporter. […]
QUESTION: In the regulations for the United States Munitions List that one dedicated individual must be named as POC or can it be multiple contacts? ========== Answers: Of course it can be multiple contacts – we have about 30 Empowered Officials at our company – we are huge! ========== “POC” is an ambiguous term in […]
QUESTION: My company hasn’t been involved with ITAR issues until we recently acquired another company. Currently our IT infrastructures remain separate, but in anticipation of migration (in small bites, over time) to a combined infrastructure, we are trying to assess the IT-related risks we must address. Does anyone have any benchmark risk guidance on the […]
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: My question relates to ITAR 120.41 Specially Designed, paragraph (b) which reads as follows:(b) For purposes of this subchapter, a part, component, accessory, attachment, or software is not specially designed if:(1) is subject to the EAR pursuant to a commodity jurisdiction determination;(2) Is, regardless of form or fit, a fastener (e.g. screws, bolts, nuts, […]
QUESTION: How does the membership identify controlled products within their ERP system whether classified under ITAR or on the CCL? =================== ANSWER: Depends on the ERP. Many ERP lack adequate functionality to support Customs/Compliance (Import/Export) work. The area is, as everyone who does this knows, quite intricate and even complex. Even where the ERP does […]
QUESTION: We have made certain types of items since the early 1980’s and have been approached by an ITAR customer. We have told them that we are not DDTC registered and that our items are commercial, and have been designed as commercial items. Nowhere on our drawings do we state any language pointing to ITAR […]
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: We exported an ITAR item to Egypt. It went to Heathrow airport but did not pass through customs. Can we just have it returned and cancel the AES. The broker is saying we have to get a DSP 61 to bring it back. If it has not entered the U.K. Customs we thought it […]
