Blog

Doing Business in Cuba Just Got Even Harder

On June 16th, 2017 the Trump Administration issued a memorandum on Strengthening The Policy of the United States Towards Cuba. Today the administration followed up on that policy shift with simultaneous Final Rules issued by the Departments of State, Treasury and Commerce, Bureau of Industry and Security. During the Obama era, there had been significant movement towards liberalizing and opening limited trade relations as well as travel opportunities with the island nation. Today’s regulatory changes represent a partial rollback of that liberalization effort and will enhance the commercial risk of entering legal trade relationships in Cuba. While the details of today’s regulatory changes are too wide in scope to fully […]

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New to Exporting? Free Online Training from ExportU

At TSI Global Consulting we regularly receive phone inquiries from individuals and firms that need entry level “new-to-export” assistance. There are of course numerous organizations that can assist. The US Department of Commerce, International Trade Administration offers a wealth of free and low cost services and the Bureau of Industry and Security has an online Export Training Room with valuable webinars that can be used for self-training. You can also contact your local office of the Small Business Administration for free or low cost export counseling. An additional resource that recently came to our attention is ExportU. Developed by the Small Business Development Center, International Trade Center at the University […]

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Beware of the Qatar Boycott: Stay Clear of Potential EAR Part 760 Boycott Violations

On June 5 2017, the  United Arab Emirates, Saudi Arabia and Bahrain effectively cut ties with the Gulf state of Qatar based on an allegation that Qatar has been supporting terrorist organizations and the Iranian regime. Among other sanctions, these three countries have adopted a boycott of trade through Qatari ports, a travel ban imposed on Qatari citizens, and a ban on Qatari aircraft from landing rights in the three countries. Under a highly byzantine and archaic section of the US Export Administration Regulations (i.e. Part 760.2 of the EAR) no U.S. person may refuse to do business with or in a boycotted country when such boycott is not recognized as legitimate […]

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BIS to Require Import License for Controlled Exports to/from Hong Kong

On January 19, 2017 the Bureau of Industry and Security published a Final Rule in the Federal Register that requires persons intending to export or re-export any item subject to the Export Administration Regulations (EAR) and controlled on the Commerce Control List (CCL) for national security (NS), missile technology (MT), nuclear nonproliferation (NP column 1), or chemical and biological weapons (CB) reasons to obtain, prior to such export or reexport, a copy of a Hong Kong import license or a written statement from the Hong Kong government that such a license is not required. Specifically, under this new rule which becomes effective on April 19, 2017 U.S exporters or re-exporters […]

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Obama Removes OFAC Sudan Sanctions in Final Week of Office, BIS Loosens Regulation on Export of Commercial Aircraft Parts and Railroad Parts to Non-Sensitive End Users in Sudan

The Bureau of Industry and Security published a Final Rule in Today’s Federal Register that changes the BIS licensing review policy from a policy of denial to a policy of approval for aircraft parts intended to ensure the safety of civil aviation in Sudan. The policy also applies to certain items for use to inspect, design, construct, operate, improve, maintain, repair, overhaul or refurbish railroads in Sudan. The general policy of approval applies for exports and re-exports to Sudan of items that are controlled for Anti-Terrorism reasons only and only items that are exported or re-exported to non-sensitive end users. Sensitive end users who are not eligible under the new […]

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License Exception TMP [Part 740.9 of the EAR] Expanded from 1-year to 4-years for Exports, Re-Exports and Transfers to Mexico’s In-Bond Industrialization Program (IMMEX)

The Bureau of Industry and Security (BIS) issued a final rule in today’s Federal Register (Vol 81, No. 231 December 1, 2016 p. 86571) which extends the time limit from 1-year to 4 years when using license exception TMP (Part 740. 9 Temporary exports, re-exports and transfers) to companies, factories or facilities in Mexico that are participating in Mexico’s in bond industrialization program (IMMEX). Under IMMEX the length of time that imports may remain in Mexico is commodity dependent with some items allowed to remain for 18 months or more. For the purpose of simplicity BIS did not match the commodity specific time limits allowed under IMMEX but rather instituted […]

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DDTC Transitioning to a Post D-Trade Era…..Finally!

Beginning November 21st, 2016 all Commodity Jurisdiction filings will be made through the new Defense Export Control and Compliance (DECCS) module. The final day for filing Commodity Jurisdictions through the online Electronic Form Submission (EFS) system will be Wednesday November 16th as the EFS is being phased out permanently as of close of business on the 16th. Eventually (almost definitely sometime in 2017) as part of DDTC’s Information Technology Modernization project, the browser based DECCS system will replace D-Trade and be used for all filings, including export license applications, with DDTC. The web based system is more user friendly as it will not require downloading forms and will allow users […]

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TSI Global Consulting Launches New Export Compliance Training Module

What is an Export Management Compliance Program? Answer: Both the operational export compliance policies and procedures an organization implements and a written set of guidelines that captures those policies and procedures. An effective EMCP answers the Why, What, Where, When, How, and By Whom your company export policies and procedures are to be implemented. Does our company need to have an EMCP? Answer: While technically not required under the U.S. Export Administration Regulations, having an internal export compliance program and manual in place is highly recommended and it is given “great weight” in mitigating fines and penalties by BIS in export enforcement cases. An effective EMCP will help ensure that […]

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BIS and DDTC Announce New Harmonized Destination Control Statement and Other Required Information on the Commercial Invoice.

In a joint announcement published in today’s Federal Register (Vol. 81 No. 159 August 17, 2016) the Department of State and Department of Commerce jointly published a Final Rule implementing a newly revised and harmonized Destination Control Statement (DCS) for ITAR and EAR transactions. The new regulations include other required data to be placed on the Commercial Invoice (see below). Note that the DCS is no longer required to be placed on the Bill of Lading, Air Waybill or other export control documents, ONLY on the Commercial Invoice. The new rule has a three month implementation period and becomes effective on November 15 2016. The new REQUIREMENTS are as follows: […]

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Required Procedures for the Sanitization and Disposal of Export Controlled Data and Technology

Does your company have a policy for safe disposal of your depreciated computers, cellular phones, PDA’s and other data storage devices that contain sensitive export controlled data? The purpose of this blog post is to take a moment to remind all of you that The Department of Commerce requires all hard drives and electronic devices that store export controlled data be thoroughly sanitized prior to disposal, transfer, or resale. What does sanitized mean? Well, the detailed guidelines for proper sanitization can be found in Special Publication 800-88 Revision 1 authored by the National Institute of Standards and Technology, a division of the U.S. Department of Commerce (NIST). Publication 800-88 Revision 1 […]

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Testimonials

International Sales are a very important part of our business. Our products are subject to strict Export Control regulations, often times requiring us to obtain an export license.Trying to keep up with export compliance regulations on your own is next to impossible.   TSI Global Consulting provides us our pathway to successful Export Compliance offering fast, courteous consulting services with a very high degree of professionalism. Thank you Jonathan Fink for all you do to make export compliance easy. It gives us the peace of mind we are doing the right thing.
Centroid Corporation