Blog Archives

Russia vs. the World

By Michael Jones ( It’s been a very long time since this blog last wrote on Russia – last time, we discussed its relationship with the U.S., and how security disagreements led to tensions over the Sochi Olympics. Of course, things have changed drastically since then. The “Euromaidan” protests in Ukraine spiraled out into full-blown regime change, Crimea declared its independence, and Russia was dragged into (willingly or otherwise) a conflict with its western neighbor over its legitimate leadership. Of course, Russia’s actions in Ukraine have also brought in a large amount of other actors into the mix; some of which have enacted sanctions against Russia in an effort to […]


BIS Tightens the Grip on Venezuela…..

On September 17th the Bureau of Industry and Security extended Part 744.21 of the EAR, formerly known in the export compliance community as the “China Military End Use Rule“, to apply in the case of exports, re-exports or transfers (in-country) to Russia. In today’s Federal Register, the beat goes on, as BIS, once again, announced a final rule, this time extending 744.21, to Venezuela. Looks like the folks over at BIS are on a roll. The extension to Venezuela was justified by BIS as a policy that was necessary to be in alignment and complement an existing U.S. arms embargo on Venezuela for its failure to cooperate in areas of […]


TSI Global Consulting: Export Guidance–Proper Compliance Screening Methodology for Commercial and Dual Use Commodities, Software and Technology

In order to ensure compliance with U.S. regulations and avoid costly fines and penalties it is extremely important that ALL export transactions whether they are EAR99, exported under an Export Control Classification Number (ECCN) that is NLR, exported under a license exception, or exported under a validated export license MUST undergo a thorough screen against ALL of the U.S. government denied/restricted parties lists. The screen should be performed just prior, ideally on the same day as the export occurs. In order to ensure compliance with U.S. export regulations you must screen both by company name and ALL major owners/shareholders of the company (i.e. see OFAC 50% rule noted below). Links […]