Blog

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 […]

Read More  j

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 […]

Read More  j

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 […]

Read More  j

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 […]

Read More  j

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 […]

Read More  j

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 […]

Read More  j

The U.S. Trade Deficit with China: Separating Fact from Fiction

In recent weeks as the Trump Administration has ratcheted up protectionist tariffs on China, much of the line of argumentation coming out of the Department of Commerce and the Office of the US Trade Representative (USTR) has centered around the need to re-balance what is perceived to be an unfair widening of the U.S.-China trade deficit. However, what is important to note is that U.S. import statistics are highly misleading. As pointed out by Douglas A. Irwin in his book Free Trade Under Fire, in 2009 the United States imported iPhones from China at a per unit cost of $US 179 adding $US 1.9 Billion to the US trade deficit. […]

Read More  j

USTR Solicits Public Comment (for possible exclusions) on Proposed List of $16 Billion of Chinese Goods To Be Subject to 25% Import Tariffs….TSI Global Consulting Can Argue for Exclusions.

The Office of the U.S. Trade Representative (USTR)  published in today’s Federal Register a notice for industry comments on $16 billion dollars of proposed section 301 tariffs to be imposed on Chinese products. The list of products slated to be subject to the tariffs (284 tariff lines baring exemptions) are noted in Annex C of the attached Federal Register announcement. An implementation date will be announced in the near future. Annex B of the attached notice denotes $34 billion dollars of Chinese goods that will be subject to 25% import tariffs effective July 6, 2018. These items have already been subject to public comment. If your company imports or purchases […]

Read More  j

It’s Tariff Time…..Round and Round We Go

President Donald Trump and his Office of the U.S. Trade Representative (USTR) announced today (June 15, 2018) the imposition of 25% ad valorum tariffs on $34 Billion dollars, 818 tariff lines of imports from China. The tariffs become effective July 6, 2018. The list of items broken down by H.S. Code subject to this new round of tariffs can be found HERE. In the coming days USTR will be publishing a process for applying for company specific exclusions. If your company is impacted by these new tariffs and you would like to apply for an exclusion please contact TSI Global Consulting, LLC. An additional $16 Billion dollars, 284 tariff lines […]

Read More  j

BIS Adds 33 Companies to the Unverified List

The Bureau of Industry and Security (BIS) announced today that 33 companies have been added to the Unverified List (UVL) [see Supplement 6 to Part 744 of the EAR]. The new additions include twelve companies in Russia, eleven in China, five in the United Arab Emirates, two in Canada and one each in Estonia, Pakistan, and Finland. As noted in previous blog postings, BIS adds persons to the UVL when they are unable to verify the bona fides of an entity through a pre-licensing or end use check. BIS often uses commercial officers in US embassies and Consulates as well as other US government officials to visit foreign entities that […]

Read More  j

Testimonials