The Raytheon Case Illustrates the Other Half of Compliance

The Raytheon Company recently entered into a consent agreement with the Directorate of Defense Trade Controls (DDTC) of the Department of State settling allegations that it violated the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR) by failing to properly manage license agreements and temporary export and import licenses. In the …

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European Commission Issues Guidelines on the Classification of Sets

On April 11, the European Commission published “Guidelines on the classification in the Combined Nomenclature of goods put up in sets for retail.” The guidelines clarify what types of goods once assembled for sale as a “set” can be classified under a single Harmonized Tariff Code rather than having to break out the items and …

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Satellites and Spacecraft Move to Commerce Control List: Proposed Rule

In a long-awaited move, the Bureau of Industry and Security (BIS) of the Department of Commerce announced a proposed rule transferring certain commercial satellite, spacecraft and related items from State Department to Commerce Department control. This proposed rule is the result of extensive efforts by the satellite and spacecraft industries in the U.S. whose exports …

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Taiwanese Father and Son Accused of Violating U.S. Laws to Prevent Proliferation of Weapons of Mass Destruction

A father and son are facing federal charges in connection with an alleged scheme to unlawfully export U.S. goods and machinery that could be used to create weapons of mass destruction. According to a May 6 press release issued by the U.S. Department of Justice, Hsien Tai Tsai, a resident of Taiwan who also goes …

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C-TPAT System of Records Notice: What does it Mean for Your Privacy?

Participants in the Customs Trade Partnership Program Against Terrorism (C-TPAT) program may be interested to know that U.S. Customs and Border Protection  has published a concurrent “System of Records Notice” (SORN) and “Notice or Proposed Rule Making” (NPRM). The recent move by CBP now brings the information that CBP has gathered on C-TPAT members and …

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The Impact of Export Control Reform on an Electronics Subcontractor

Acme Electronics (Acme) is a medium-sized company in the U.S. that makes products (primarily circuit board assemblies and wiring harnesses) used in commercial and military aircraft. Acme occasionally sells these products to aircraft manufacturers, but most of its sales are to major U.S. and foreign subcontractors to aircraft manufacturers. Acme has a pretty straightforward process …

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Blue Lantern Highlights the Need for a Strong Compliance Program

The Department of State, through the Research & Analysis Division (RAD), Office of Defense Trade Controls  Compliance (DTCC), Bureau of Political-Military Affairs (PM) operates an end-use monitoring program called Blue Lantern. The Blue Lantern program monitors the end-use of defense articles, defense services, and brokering activities to ensure that “the recipient is complying with the requirements …

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2012: A Busy Year for Customs and Border Protection

U.S. Customs and Border Protection (CBP) recently released a summary of its activities in Fiscal Year 2012, which the agency says was marked by “historic levels of personnel, technology and resources” dedicated to the Southwest border, coupled with efforts to facilitate legitimate trade and travel. “In 2012, the men and the women of CBP played …

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Making a “Made in USA” Claim – First Understand the Basics

Both the Federal Trade Commission (FTC) and U.S. Customs and Border Protection (CBP) have responsibilities related to the use of country-of-origin claims. While the FTC regulates claims of U.S. origin under its general authority to act against deceptive acts and practices, foreign-origin markings on products (e.g., “made in Japan”) are regulated primarily by CBP. This …

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An Update on Export Control Changes for Commercial Satellites

Recent movement toward loosening export controls for commercial satellites and related items has that sector of U.S. industry crossing its fingers. Notably, the President recently signed into law an act loosening export controls. The National Defense Authorization Act of Fiscal Year 2013 (“the Act”), signed on January 2, is a signature step in the movement …

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Conducting Business in Mexico in 2013…..Is it Safe?

Last month, I covered the ever-growing competitive landscape between manufacturing in Mexico and manufacturing in China. Interestingly, some of you inquired about the obvious risks (non-Customs related) involved with manufacturing in Mexico, so I thought I would take a look at the current climate. It’s a given that Mexico’s war on crime is  a point …

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Trade between the United States and Mexico: Securing the Supply Chain

The trade of goods and services between the United States and Mexico is an essential component of both countries’ economies. As of 2011, the trade of goods and services with Mexico totaled $500 billion. Mexico was the second largest market for exports of U.S. goods, and the third largest supplier of goods imported into the …

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Bureau of Industry and Security “Outreach visits”: An Opportunity to Shape Up

On Feb. 5, 2010, a small company named Capintec, Inc. received a seemingly cordial and routine “outreach visit” from Bureau of Industry and Security (BIS) special agents. What appeared to be a harmless and informative visit turned out to be the Trojan horse that led to a $23,000 fine assessed against Capintec for unauthorized shipments …

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Adrienne Braumiller and Bruce Leeds to speak at the 12th Annual Partnering for Compliance- East Coast Conference

DATE: February 20, 21 & 22, 2013 *Reservations are limited to the first 200 paid registrants. COST: Pre-registered and prepaid before Monday, February 4th, 2013- $450.00, Non-U.S. Government. $150.00 U.S. Government Employees All registrations received after Monday, February 4th, 2013- $495.00, Non-U.S. Government. $190.00, U.S. Government Employees LOCATION: Pegasus Ballroom (Student Union Building), University of Central …

Read moreAdrienne Braumiller and Bruce Leeds to speak at the 12th Annual Partnering for Compliance- East Coast Conference