Export Licensing & Compliance

A small selection of our recent client engagements include:

Aerospace Export Compliance Advisory & Licensing:  We recently took on a consulting engagement with a U.S. aircraft parts exporter to classify against the Commerce Control List (CCL) an entire aircraft manufacturing program that included a 1970s era single engine aircraft inclusive of over 14,000 parts, components, blueprints, jigs and molds for sale to a commercial end user in the Peoples Republic of China. In another case, we handled the ITAR/EAR jurisdiction determination, classification and licensing of ground positioning equipment manufactured by a California company for export to the Royal Air Force (UK). In 2017, on behalf of a Florida based exporter we advised on, drafted, filed and obtained a third party “bulk” BIS license for $6 million dollars of “series 600” C-130 parts to Latin America  We also assisted a US aircraft engineering company to determine licensing jurisdiction, classification and successfully guided them through the process to obtain a $22 million dollar ITAR license for the export of a small fleet of fixed wing and rotary wing Intelligence, Surveillance and Reconnaissance (ISR) aircraft platforms. And We worked on behalf of a Connecticut based aerospace electronics manufacturer to successfully draft, file and obtain a commodity jurisdiction review from the Department of State for a dual use breathing device used for high altitude flight simulation.
 
Aerospace Export Compliance TrainingAt TSI Global Consulting we designed two proprietary export compliance training modules covering the recent export control reforms in the aerospace industry that incorporate the new “series 600” ECCNs for commodities, software and technology that has moved from the U.S. Munitions List (USML) to the Commerce Control List (CCL) . TSI Global Consulting Managing Director Jonathan Fink has used the modules to conduct onsite corporate training to over ten aerospace manufacturers and distributors located in California, Arizona, New York and Florida. At one of our onsites he trained a sales force of over 30 personnel at a U.S. 25 Million dollar distributor of commercial and military aircraft parts. Training was also conducted onsite at the plant location of an original West coast based manufacturer of air frame parts for the C-130 military cargo plane. In 2017 we we contracted a 2-day onsite to train the management of an Arizona based military aircraft parts distributor on EAR/ITAR compliance for licensed exports of parts and components used with several US origin military aircraft platforms in operation with military allies in Asian markets. We also assisted the Arizona company to successfully obtain a $3 million dollar bulk export license from BIS for military aircraft parts.

Oil and Gas Industry/Licensing:

We contracted with a $US 400 million dollar Houston, Texas based energy company to draft, file and obtain a BIS export license for export controlled nickel valves to the Saudi Arabia ARAMCO-SAMREF oil refinery. We also advised a Florida based steel and metal alloy distributor to successfully obtain an export license from the U.S. Department of Commerce, Bureau of Industry and Security (BIS) for the export of aluminum round bars (ECCN 1C202) controlled for nuclear proliferation to Mexico for processing into tools used by a Fortune 500 U.S. corporation operating in the oil and gas industry.

Strategic Metals/Licensing:

Working on behalf of a U.S. based exporter of raw materials we drafted, filed, and obtained a license from BIS to export $2 Million dollars of zirconium and hafnium controlled for nuclear proliferation to the Peoples Republic of China for manufacture of “getters” used as insulation for semiconductors and a wide range of commercial products. In 2017 we drafted, filed and obtained a $500,000 license on behalf of a US subsidiary of a Chinese owned company to export Hafnium for commercial end uses in China.

Semiconductors/Export Classification:

We advised a Singaporean based re-seller of semiconductor tooling to determine ECCN classification and licensing requirements under the U.S. Export Administration Regulations (EAR) for semiconductor tooling warehoused in the United States and scheduled for export to South Korea and Singapore.

Information Technology/Encryption Registration and Review:

We took work on behalf of a Los Angeles based manufacturer of LCD display boards to classify encryption capable microchips for export to the Peoples Republic of China. Drafted and filed an encryption registration application with the Bureau of Industry and Security through the SNAP-R system.

Crime Control Products:

We consulted a California based wholesale/retail company and successfully obtained a BIS export license to export fingerprinting dyes and inks to a distributor in Brazil for resale to the Brazilian police.

Military Electronics/ITAR:

Advised the senior management of a Panamanian company that brokers military electronics to the Panamanian government on their obligations as a broker of defense articles listed on the USML under Part 129 of the International Traffic in Arms Regulations.

Satellite Tracking Systems:

We advised on, drafted, filed and obtained from the Department of State a Commodity Jurisdiction for a Virginia based firm that designed technology used to track satellite interference location sources.

Medical Device/OFAC Licensing:

Worked on behalf of a New England based manufacturer of medical devices to draft and file a license with the U.S. Treasury Office of Foreign Assets Control (OFAC) for export to a sanctioned country.

Machine Tools/BIS Licensing:

TSI Global Consulting has for the past five years served as the outsourced export compliance division for a major American manufacturer of CNC  machine tools that are classified under ECCN 2B201 and controlled for nuclear proliferation. On behalf of this client we have advised on EAR regulatory requirements, drafted, filed and obtained over ten BIS export licenses accounting for millions of dollars of CNC 5-Axis machine exports to numerous markets in the Middle East and Latin America.

Cuba: Export Compliance and Licensing

In 2017 TSI Global Consulting was retained to advise on EAR regulations and licensing by a major hardware manufacturer that wanted to export building construction supplies to Cuba. The niche opportunity developed as a result of recent regulatory liberalization initiatives that were put into place by the waning Obama Administration which allowed for some limited exports of construction material to the private sector in Cuba as an exception to the ongoing trade embargo. We also assisted the company in navigating and ensuring compliance with the Cuban Assets Control Regulations or CACR administrated by the US Department of the Treasury, Office of Foreign Asset Controls (OFAC).

 

TSI Global Consulting also provides client services in a wide range of other export/import compliance matters, including filing of the Electronic Export Information or “EEI” through the Automated Export System (AES), Schedule B tariff classifications and filings for binding tariff rulings from U.S. Customs.

Explaining complex government tariff, trade and foreign investment regulations to our clients in an easy to understand manner is the core competency of TSI Global Consulting.

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