International Trade Alert: Bureau of Industry and Security Announces Intra-Company Transfer License Exception

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After years of requests from the export community, the Bureau of Industry and Security (BIS) finally proposed creation of the Intra-Company Transfer (ICT) license exception. It was published in the October 3, 2008 Federal Register and was introduced at BIS Update 2008 by Christopher Wall, BIS assistant secretary for export administration. The proposed license exception could eliminate the need for licenses for most exports of goods and technology between U.S. companies and their foreign operations.

But (and yes, there is a but), there are strings attached and qualifying to get BIS approval to use the ICT will not be as easy as industry had hoped. To use the ICT license exception, an exporter will be required to obtain advance BIS approval, part of which will include adoption of an ICT ?control plan? and agreement to allow BIS to conduct audits of the exporter. In addition, use of the ICT exception will impose recordkeeping requirements for all trade conducted under the exception and all foreign persons authorized to have access to controlled technology under the exception.

Please see full alert for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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