Note to our clients and U.S. exporters. Are you are taking advantage of license exception STA which allows for the export, re-export and transfer (in-country) of a very wide range commodities, software, and technology that ordinarily require licensing to a group of 37 countries that are close allies of the United States as defined in Country Group A:5 (supplement 1 to Part 740 of the EAR)? At TSI Global Consulting we have found that many companies are not taking advantage of the availability of this license exception. While there are important paperwork conditions that are required prior to shipment using STA (i.e. advanced notification that the pending shipment will be made under STA authority as well as certification/signature of a Special STA Consignee Statement, we have nonetheless found that with a little guidance exporters can easily use STA in lieu of licensing for many export transactions to both government and non-governmental entities. Most Series 600 equipment, parts and components are STA eligible which allows for quick shipment and end use by the military or government agencies of friendly cooperating countries. There are a good number of carve ins and carve outs to be aware of when using STA, so each export needs to be “qualified” by competent export compliance personnel and you need to pay close attention to both the requirements noted in § 740.20 as well as situations where license exceptions are prohibited as noted in EAR § 740.2. In addition, you need to be sure that you have the properly signed and dated Consignee Statement in your files prior to shipment as BIS is known to conduct post shipment desk audits to check paperwork (subject to export enforcement if not properly executed) and ensure companies are in regulatory compliance with use of the license exception. But we have found that when available for use, the benefits of using STA iif lieu of using a license grossly outweigh the costs. It’s not that hard! EEI is required for all shipments that use STA regardless of value.
You too can be easily trained to use this widely available license exception. Contact TSI Global Consulting for further information/details on how to use the Strategic Trade Authorization or “STA” in compliance with the EAR and to explore if and how this license exception may be available to your company.
