Matt Silverman on Export Compliance
License Exception MED - On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule for a new license exception for “medical devices” under § 740.23 of the EAR (“License...more
The US Department of Commerce’s Bureau of Industry and Security (BIS), which administers the Export Administration Regulations (EAR) and regulates most exports from the United States, announced further updates to the process...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more
ACI’s highly anticipated Proficiency Series on Economic Sanctions provides true immersion into Economic Sanctions with the objective of becoming proficient in 4 weeks. Advance your career and professional development by...more
On September 26, 2023, the “Export Enforcement Five” or “E5” partnership among the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance focused on preventing Russian...more
As the only comprehensive, practical event of its kind in the Unites States, ACI is hosting the highly anticipated 5th Annual U.S.-China Trade Controls Conference, scheduled for October 12–13 in Washington, DC. Considering...more
ACI’s highly anticipated Proficiency Series provides true immersion in the EAR with the objective of becoming proficient in four weeks. Join virtually from September 12 – October 5, 2023! Advance your career and...more
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) continues to send a strong and clear message to the exporting community – it wants businesses and universities to voluntarily disclose any significant...more
On February 8, 2022, the US Department of Commerce’s Bureau of Industry and Security (BIS) added 33 Chinese entities to the agency’s Unverified List (UVL). The UVL does not fully prohibit transactions with the designated...more
The U.S. government recently took action in two cases against companies for exports to distributors that resold their products to prohibited parties. The products at issue in both cases are designated "EAR99," which is a...more
Please note: This Holland & Knight alert has been updated on Sept. 13, 2021, with additional information. In plain English, anytime an aircraft departs the United States, this is an "export" and will fall in one of two...more
The U.S. Foreign Military Sales (FMS) Program offers government contractors and suppliers to the U.S. defense industry valuable access to markets outside the United States and to bona fide customers in those markets. The FMS...more
Few areas of compliance change as rapidly as export controls. People, companies and even countries move on and off the sanctions list. Adding to the complexity, as Matt Silverman, Senior Manager, Compliance & Export Control...more
Today, the Bureau of Industry & Security (BIS) is amending the Export Administration Regulations (EAR) to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption...more
There are two common types of aircraft exports: 1) permanent exports – where the aircraft is physically exported (i.e., flown) from the U.S. as part of a sale, lease or transfer of possession and control to a foreign person,...more
One of the most enduring questions of business executives and export professionals is how does the government learn about export violations? If my company has a possible violation, what are the chances that the government...more
On October 16, 2020, the Bureau of Industry and Security (BIS) announced that exporters may request a six-month extension for export licenses set to expire on or before December 31, 2020....more
Target areas are telecom, information security, and sensor items that can be used for censorship, surveillance, detention, and use of force. On October 6, 2020, the US Department of Commerce, Bureau of Industry and...more
American Conference Institute (ACI) will host a one day virtual conference to discuss timely changes to the export controls regulations. Join key government officials, in-house decision-makers, and the “who’s who” of the...more
On August 17, 2020, the U.S. Department of Commerce Bureau of Industry and Security (BIS) made available for public inspection a final rule expanding restrictions on Huawei Technologies Co., Ltd. and its non-U.S. affiliates...more
This software now requires a BIS authorization to be exported or reexported to all countries except for Canada. Companies that develop or use artificial intelligence (AI) to solve geospatial problems or in geospatial...more
In a rule published and effective October 9, 2019, China’s key manufacturers of video surveillance products have been added to the Bureau of Industry and Security (BIS) Entity List by an interagency End-User Review Committee...more
A set of changes to the U.S. dual use export control rules makes exporting sensitive goods, software, and technology to India less burdensome. Over the last several years, India has joined three of the four major...more
As part of the ongoing Export Control Reform initiative, the Directorate of Defense Trade Controls (“DDTC”) and Bureau of Industry and Security (“BIS”) has issued proposed rules that would move certain items currently...more
• The U.S. Bureau of the Census has issued a notice requesting comments on the definition of “routed export transaction” and the responsibilities of parties in routed export transactions. Comments are due by December 5, 2017....more