Weekly Roundup-Notables in the World of Export Controls

A few notables from this week in the world of US export compliance regulations and ongoing client work here at TSI Global Consulting include:

 

  • Cuba Call-In: The U.S. Department of Commerce, Bureau of Industry and Security announced that a new monthly call in teleconference will be offered to explain regulations and field questions from the exporting community associated with the new January 15th Cuba Rule. The Cuba Rule allow for exports of some consumer communications devices and telecommunications equipment under license exception Support for the Cuban People (SCP). The rules also expand travel under a general license. The official version of the Cuba Rule from the January 15th Federal Register can be accessed here. The first open teleconference will be held on May 12th at 2:00 P.M. eastern time. Additional sessions are scheduled for June 9, July 7 and August 11th at 2:00 P.M. Complete details for joining the teleconference can be found here.

 

  • Proposed Rule for Changes to Category XII of the USML: On Tuesday May 5th the Department of Commerce and Department of State published simultaneous proposed rules related to export control reform for Category XII (fire control, range finder, optical and guidance and control equipment)  related defense articles (specifically image intensification tubes “IITs” and infrared focal plane array detectors “IRFPAs.”) The proposed rules contain a very lengthy positive list of IITs and IRFPAs that are slated to remain in Category XII. The propose rule maintains language in which commercial products that contain IR focal plane arrays are not listed in Category XII provided the components cannot be removed from the commercial system without being destroyed or rendered inoperable. How that determination of “inoperable” is made and documented is left vague and undefined. The specific proposed rules can be found here (BIS) and here (DDTC). Both BIS and DDT are soliciting comments on the proposed rules. For further details contact TSI Global Consulting.

 

  • BIS “Blanket Licenses” for Series 600 parts and components: Just FYI, those of you who are exporting high volumes of a wide range of 9A610 and 9A619 parts and components, it is not widely known or published, but yes, BIS is issuing blanket/bulk export licenses for series 600 parts and components, at least in the 9A610 and 9A619 series. DoD is requesting a non-all inclusive representative list of parts to accompany the license application, but otherwise “miscellaneous up to $1” is an acceptable format. At TSI Global Consulting our first “blanket” license was submitted to BIS earlier this week and inside sources tell us it will be approved so yes, it can be done. Sources close to our firm also tell us that DoD is accepting and approving BIS blanket license applications for miscellaneous series 600 parts/components up to $5M, a pleasant surprise in the world export control reform which should be highly beneficial to our clients.
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