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 counter terrorism. The Federal Register also noted that this action is taken in response to abuses committed by the Venezuelan military on the People of Venezuela. The rule becomes effective today (November 7, 2014). Our word-for-the-wise in the exporting community is to use caution on your commercial exports of items listed in Supplement 2 to Part 744 of the EAR to Venezuela. That extra due diligence on end users and end use and perhaps use of an end use statement/letter of assurance would be a very good idea when exporting items to Venezuela that are subject to the new “Venezuela Military End Use Rule.” For further information contact our office.
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