Thomas McVey

Thomas McVey

Williams Mullen

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Trade Compliance Issues in the New Administration, Part I: Export/Sanctions Laws

A change in administration will likely bring changes in export/sanctions laws and compliance obligations. This will include both last minute amendments by the outgoing administration and initiatives by the new President....more

11/16/2016 - Compliance Cuba EAR Economic Sanctions Export Controls Foreign Relations Iran Russia Trump Administration

“Reason To Know” – A Chilling Term For Exporters

It’s a simple question – if a U.S. exporter sells its product to a foreign customer, and the customer resells the product to a prohibited country such as Iran, can the U.S. exporter have liability for an export violation? ...more

9/23/2016 - Chief Compliance Officers Due Diligence Electronics Export Controls Exporters Iran OFAC

State Department Relaunches Company Visit Program to Assess ITAR Compliance

The Directorate of Defense Trade Controls (“DDTC”) within the State Department has relaunched its “Company Visit Program.” Under the Company Visit Program, DDTC officials come to your office to review your company’s...more

9/14/2016 - Audits Compliance DDTC ITAR US Department of State Visas

New Guidance on ITAR Registration in the Firearms Industry

The State Department has issued new policy guidance regarding the requirement for gunsmiths and others involved in the firearms industry to register with the State Department under Part 122 of the International Traffic In...more

8/24/2016 - DDTC Firearms ITAR Manufacturers New Guidance US Department of State

ITAR For Government Contractors: Revised For Recent Amendments

One of the most important areas of regulation for defense contractors is the International Traffic In Arms Regulations (“ITAR”). ITAR are the State Department controls that regulate the defense industry. Companies regulated...more

7/21/2016 - Amended Regulation Commerce Control List Cybersecurity Defense Sector Department of Defense (DOD) DFARS EAR Export Controls Federal Contractors ITAR NATO Registration Requirement US Department of State USML Voluntary Disclosure

USA FDI News - April 2016

USA FDI News highlights the FAQs arising from your projects - from how to finance a deal to selecting the right visa or tax strategy and more. We want to keep USA FDI News interactive and relevant to your international...more

4/13/2016 - Affordable Care Act Community Trademark Cuba Drinking Water Economic Sanctions EU Export Controls Financing FIRPTA Foreign Banks Foreign Direct Investment Intercompany Transactions Iran Sanctions Lead Letter of Credit Manufacturing Facilities Parent Corporation Pension Funds Protecting Americans from Tax Hikes (PATH) Act REIT Visa Waiver Program Withholding Requirements

Key Export Compliance Issues For 2016

The following are a number of important strategic issues to be considered in the export compliance area for the new year. 1. Recent Country Amendments – New Obligations and New Opportunities. There have been export...more

2/11/2016 - Aircraft BIS Commerce Control List Corporate Counsel Cuba Cybersecurity DDTC Export Controls General Licenses Iran Personal Liability Popular US Munitions List

Williams Mullen FDI USA News - December 2015

FDI USA News highlights the FAQs arising from your projects—from how to finance a deal to selecting the right visa or tax strategy and more. We want to keep FDI News interactive and relevant to your international business. ...more

12/22/2015 - Due Diligence EB-5 Foreign Direct Investment Trade Secrets Visas

Corporate Officers Charged Personally for Export Violations

A South Carolina company, Streit USA Armoring LLC (“Streit USA”), along with two of its executive officers and its UAE affiliates, were charged with export control violations in connection with the sale of armored vehicles to...more

11/18/2015 - C-Suite Executives Corporate Crimes Enforcement Actions Export Controls Personal Liability UAE

Proposed Amendments Provide Data Security Standard Under ITAR and EAR

The Commerce and State Departments have issued long-awaited proposed regulations that provide data security standards for use in the transmission and storage of ITAR-controlled and EAR-controlled electronic data. If enacted...more

9/16/2015 - Cloud Computing Data Security EAR Electronic Data Transmissions Encryption Export Controls Harmonization Rules ITAR Proposed Regulation U.S. Commerce Department US Department of State

Iran Nuclear Agreement – Mixed Bag for U.S. Exporters

The Iran Nuclear Agreement provides certain opportunities for U.S. firms, but these are not as significant as many U.S. business executives had hoped. The following are highlights of the most important provisions of the Iran...more

9/10/2015 - Export Controls Exports Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC

Proposed ITAR Amendment Provides Important Benefit for Government Contractors

The Directorate of Defense Trade Controls (“DDTC”) has issued a proposed regulation under the International Traffic In Arms Regulations (“ITAR”) that will have a significant impact on government contracts firms. Under the...more

7/10/2015 - Arms Export Control Act DDTC EAR Export Controls Federal Contractors Imports ITAR Proposed Regulation US Department of State

Export Control Laws for the General Counsel

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

6/11/2015 - Arms Embargo Arms Export Control Act Blocked Entities Blocked Person Chief Compliance Officers Compliance Defense Sector Due Diligence EAR Embargo End-Users Export Administration Regulations Export Controls Exports ITAR Know Your Customers Manufacturers Military End Use OFAC Sanctions Software Software Developers Technology

ITAR/EAR Amendments for Military Electronics Become Effective December 30

The amendments affecting military electronics products under Export Control Reform become effective on December 30, 2014. This will cover a large number of products in the electronics, computer, telecom and avionics...more

12/23/2014 - Defense Sector EAR Electronics Export Controls ITAR Military End Use

New Export Control Requirement for Electronics Manufacturers in Defense and Aerospace Industries

The State and Commerce Departments recently issued significant new regulations under Export Control Reform affecting the export control requirement for military electronics. These will have a major impact on manufacturers of...more

11/7/2014 - Aerospace Defense Sector Electronics Export Controls Federal Procurement Systems Manufacturers Telecommunications U.S. Commerce Department US Department of State

Special Due Diligence Concerns When Buying Unmanned Aerial Systems

The regulatory lid is about to come off domestic commercial use of Unmanned Aerial Systems (“UASs”). When that happens, like a vacuum, the U. S. commercial market will seek to deploy every viable system. In the rush to...more

3/13/2014 - Drones Due Diligence Federal Aviation Administration (FAA)

Fourth Circuit Holds That Defendant Can Be Guilty of Criminal Violation of Armed Export Control Act Even Without Specific...

To obtain a felony conviction under the Arms Export Control Act for “willfully” exporting “defense articles” without a license, must the government prove that the defendant knew the items in question were specifically subject...more

1/31/2014 - Arms Export Control Act Convictions Exports Felonies Firearms

Initial Provisions of Export Control Reform Become Effective October 15th – Steps to Take to Prepare for Export Control Reform

On October 15, 2013 the first major series of amendments under the Export Control Reform will go into effect. Every exporter should be aware of these amendments and have a plan to prepare for these changes....more

10/11/2013 - Export Controls ITAR

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