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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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TSI Global Consulting to Offer Pro-Bono Export Licensing and General Import/Export Assistance for equipment used to manufacture medical supplies

Effective immediately, TSI Global Consulting, LLC is offering no cost export licensing and general export regulatory assistance to any of our clients that are importing or exporting medical supplies and/or machine tools used to alleviate the current COVID crisis. Manufacturers of CNC and other machine tools that are subject to US export licensing will receive expedited service from TSI Global Consulting, LLC in advising on, drafting and filing licenses. Provided end use is related to helping out with the COVID crisis, all services will be provided at no cost. Call the office if you wish to discuss 210-757-0618.

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DDTC Issues Interim Final Rule Making Important Changes to Transmission of Encrypted ITAR Technical Data

On December 26th, 2019 the Department of State published in the Federal Register (Volume 84, No. 247 an interim final rule that will, effective March 2020 amend the International Traffic in Arms Regulations (ITAR) to a) define activities that do not constitute an export, re-export, re-transfer or temporary import, b) create a new definition of “access information” and 3) revise the current ITAR definitions of export, re-export, re-transfer, temporary import and release. While the technical changes noted in this interim final rule are too extensive and detailed to cover within the context of a brief blog post, by far the most important change relates to the manner in which DDTC […]

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BIS/OFAC Walk Back Obama Era Cuba Travel Regulatory Reforms

With simultaneous FINAL RULES scheduled to be published in tomorrow’s (June 5th, 2019) Federal Register, both OFAC and BIS will, effective tomorrow, be rescinding liberalization of travel rules that were enacted in the waning days of the Obama Administration. Specifically, with regard to BIS, tomorrow’s final rule amends license exception AVS (temporary sojourn of aircraft, vessels and spacecraft) effectively removing use of this license exception for passenger and recreational vessels from making temporary sojourn to Cuba. Under the new rule, AWS will no longer apply for cruise lines (and many aircraft as well) and BIS licenses for cruises will be subject to a presumption of denial (sorry, looks like no […]

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Venezuela Moved from Group B to Group D

The U.S. Department of Commerce published a Final Rule in today’s Federal Register officially moving Venezuela from country Group B which provides favorable treatment for certain exports of national security concern to Group D:1  Countries of National Security concern. This new announcement also places Venezuela into Country Groups D:2-4 which contains countries of concern for nuclear, chemical and biological weapons and missile technology. The movement to Group D negates the potential to use certain license exceptions found in Part 740 and subjects Venezuela to the  stricter “case-by-case” licensing requirements on exports to countries of National Security Concern delineated in Part 742.4 of the EAR. The rule is effective as of […]

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BIS Adds 50 to the Unverified List

In today’s Federal Register The Department of Commerce Bureau of Industry and Security published the addition of fifty entities to the Unverified list. In addition, ten companies were removed from the UVL based on new information received from BIS. Clients should take note that entities listed on the UVL are not barred from receiving U.S. exports. However, BIS has flagged these entities for potential unauthorized diversion due to the inability of BIS officials to confirm the bona fides of such entities. In the event you are considering an export, re-export or in-country transfer with/to a UVL listed entity, you may NOT use any license exceptions and you must obtain a […]

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An $US 80,000 Invoice for a 5-Minute Shortcut

Yes, the U.S. Department of Commerce, Bureau of Industry and Security may have been shut down from December 20th 2018 until it re-opened this past Monday, but that did not stop Export Enforcement from levying an $US 80,000 charging letter and invoice to Ithaca, New York based Multiwire Laboratories, Ltd. for its failure to take five minutes out of its business day back in February 2014 and August 2015 when on two occasions it exported two Real Time Back Reflection Laue Cameras valued at $177,156 to the University of Electronic Science and Technology (“USETC”) of China based in Chengdu. Problem was, Multiwire had no export compliance screening (a five-minute routine […]

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U.S. Government Shutdown/Impact on Licensing

A note to our clients: Unfortunately, due to the U.S. government partial shutdown all export compliance filings with the Department of Commerce, Department of State and Treasury Department are  on hold and frozen (with the exception of urgent cases for direct needs by the U.S. military or humanitarian assistance). The official announcement from the BIS/SNAP-R filing site reads as follows: “Due to the lapse in funding affecting the Department of Commerce that occurred at 12:01 AM EST on Saturday, December 22, 2018, services at BIS are significantly curtailed, including requests for licenses, advisory opinions, and commodity classification except those that provide direct support to the U.S. military, humanitarian aid, or […]

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New Russia Sanctions: Arms Embargo + Prohibition/Policy of Denial for National Security Controlled BIS licenses.

On Monday August 27th the Department of State published a Federal Register announcement introducing new sanctions effective immediately on Russia. This round of sanctions is in retaliation for Russia’s violation of international law through the use of chemical weapons. The case refers to the March 2018 use of a military grade nerve agent that took place the United Kingdom in an attempt take the life of Sergei Skripal, a former Russian intelligence officer who was accused of working as a double agent for the UK. Two British nationals, one of whom later died, were exposed to the chemical agent. Under the new sanctions which are tied to the unlawful use […]

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