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BIS Expands Export, Re-Export and Transfer Controls for Military End Use or Military End Users in China, Russia and Venezuela.

In a FINAL RULE published in the April 28, 202 version of the Federal Register, the Bureau of Industry and Security announced a tightening and expansion of export controls related to military end users and end use in China, Russia and Venezuela. The new Rule becomes effective June 29, 2020. The key provisions of this new rule include: — Expansion of the licensing requirement in Part 744.21 of the EAR to include military end users in China. The current/previous rule requires licensing for military end use in China. — Broadening the definition of “military end use” by identifying each category of “use” so that that export of commodities, software or […]

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What is NOT an Export, Re-Export, Re-Transfer or Temporary Import?

On March 26th the U.S. Department of State published a FINAL RULE amending the ITAR effective immediately with a series of long awaited revisions and clarifications on activities that are NOT considered exports, re-exports or re-transfers and thus do NOT require licensing authorization by the Directorate of Defense Trade Controls (DDTC). While this new regulatory change contains many new wrinkles, two of the major changes to the ITAR that TSI Global Consulting sees as important elements for our clients include: Export, Re-Export and Re-Transfer of unclassified ITAR controlled technical data does NOT require authorization if such data is exported [with the exception that such data may not be “intentionally” exported, […]

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