Blog Archives

BIS Proposes to scrap the Comprehensive Export License (Part 752 of the EAR)

In today’s Federal Register (Tuesday, September 30th) the Bureau of Industry and Security (BIS) issued a proposed rule to eliminate Part 752 “The Special Comprehensive License” from the EAR. Originally put into place back in 1997, the Special Comprehensive License (SCL) was intended to allow firms to obtain a bulk distribution license which would, for all intents and purposes, allow an applicant to export or re-export to multiple end users in different countries via one bulk license authorization from BIS provided the applicant goes through an extensive process to “prove” to BIS through audits, onsite visits by governments officials and lots of paperwork, that it has developed a highly sophisticated […]


BIS imposes the “China Military End Use Rule” for Exports to Russia

In the ongoing ratcheting up of economic sanctions against the Putin regime it was announced in today’s Federal Register (79 FR 55608 dated September 17, 2014) that the Bureau of Industry and Security is effectively extending the China Military End Use Rule for exports to Russia. In the new rule which becomes effective as of today (September 17, 2014) BIS has amended Part 744.21 of the EAR by adding “Russia” after “Peoples Republic of China” or “PRC” wherever those names appear in this section. What does this mean? In short, a range of ECCN’s that normally for most countries do not require a validated export license, will now require a BIS license if exported, […]


Is there such a thing as a $0 value transaction? The case of $1 making a 45 day difference in processing a BIS export license!

This week, here at TSI Global Consulting, we have been working on a BIS export license application for a client that needs to export some export controlled equipment (we will leave out the specifics for client confidentiality reasons). The export is for temporary demonstration which brought up an interesting issue. Intuition says, use $0 as value on the export license application. After all, this is not an export sale and the equipment will be brought back into the USA after it has been previewed and shown around in the market by the potential distributor. We were even advised by an export counselor at BIS to do exactly that, use $0 […]