Blog Archives

Did You Know About the China Military End Use Rule (Part 744.21 of the EAR)

15 CFR Part 744.21 states that all items subject to the EAR which are listed in Supplement 2 to Part 744 may not, without a BIS validated export license, be exported, re-exported or transferred to the Peoples Republic of China if you have knowledge that the item is intended entirely or in part, for military end use.  It should be noted that some very common ECCN line items are subject to the China Military end use rule, including such things as commercial aircraft parts falling under ECCN 9A991 (as well as software 9D991 and technology 9E991), navigation/direction finding equipment classified under 7A994, some telecommunication equipment classified under 5A991, some select […]


BIS Issues Newly Revised “Don’t Let This Happen To You” Enforcement Report……

The Bureau of Industry and Security has released a long awaited revised (July 2014) edition of the “Don’t Let This Happen To You” report which provides case synopses of companies and individuals who have been subjects of civil and criminal actions for export control violations. While there is nothing “new” in the report it does provide a good overview of what constitutes good export compliance procedures and it outlines factors that BIS takes into consideration when determining an appropriate administrative penalty for violations of the export administration regulations. Exporters should note the following variables which BIS uses to assess fines and penalties: General Factors for consideration include: Destination of the […]


ISIS, Iraq, and Why it All Matters

By Michael Jones ( “WaziriyaAutobombeIrak” by U.S. Navy photo by Mass Communication Specialist 2nd Class Eli J. Medellin –; exact source. Licensed under Public domain via Wikimedia Commons.   In America, the issue of Iraq has largely been seen as cleaned up over the past few years.  We went in, took Saddam Hussein out of power, and withdrew our troops, and due to the messy and morally grey area of the conflict, most Americans were happy to put it out of our collective minds.  Since  the end of the Iraq War, different conflicts in the Middle East have flared up, and now Egypt, Syria, and continued conflicts in Afghanistan […]