A small selection of our recent client engagements include:
Aerospace Export Compliance Advisory Services and Licensing
We recently took on a consulting engagement with a U.S. aircraft parts exporter to classify against the Commerce Control List (CCL) an entire aircraft manufacturing program that included a 1970s era single engine aircraft inclusive of over 14,000 parts, components, blueprints, jigs and molds for sale to a commercial end user in Asia. In another case, we handled the EAR jurisdiction determination, classification and licensing of ground positioning equipment manufactured by a California company for export to the Royal Air Force (UK). In 2021, on behalf of a Florida based exporter we advised on, drafted, filed and obtained a third party “bulk” BIS license for $6 million dollars of “series 600” C-130 parts to Latin America. And in 2020 we handled the advisory and licensing for a Florida based aerospace parts distributor on C-130 parts exported to Argentina. We also handled licensing for a California based distributor’s export of ECCN 9A610 military aircraft parts to the Malaysian and Indonesian Air Force. And we assisted a US manufacturer based in Connecticut to obtain an export license for original manufactured parts that were exported to Embraer (Brazil) for integration onto a military aircraft. And since 2019 we have served as the lead export compliance consultant on EAR and ITAR licensing to the senior management of a Texas based OEM that has designed and produced a unique first generation dual use (commercial/military) Unmanned Aerial Vehicle (UAV) system that competes with systems developed by Boeing. We also assisted a US aircraft engineering company to determine licensing jurisdiction, classification and successfully guided them through the process to obtain a $22 million dollar ITAR license for the export of a small fleet of fixed wing and rotary wing Intelligence, Surveillance and Reconnaissance (ISR) aircraft platforms. And we worked on behalf of a Connecticut based aerospace electronics manufacturer to successfully draft, file and obtain a commodity jurisdiction review from the Department of State for a dual use breathing device used for high altitude flight simulation.
Aerospace Export Compliance Training:
At TSI Global Consulting we designed two proprietary export compliance training modules covering the recent export control reforms in the aerospace industry that incorporate the new “series 600” ECCNs for commodities, software and technology that has moved from the U.S. Munitions List (USML) to the Commerce Control List (CCL) . TSI Global Consulting Managing Director Jonathan Fink has used the modules to conduct onsite corporate training to over ten aerospace manufacturers and distributors located in California, Arizona, New York and Florida. At one of our onsites he trained a sales force of over 30 personnel at a U.S. 25 Million dollar distributor of commercial and military aircraft parts. Training was also conducted onsite at the plant location of an original West coast based manufacturer of air frame parts for the C-130 military cargo plane. In 2017 we we contracted a 2-day onsite to train the management of an Arizona based military aircraft parts distributor on EAR/ITAR compliance for licensed exports of parts and components used with several US origin military aircraft platforms in operation with military allies in Asian markets. We also assisted the Arizona company to successfully obtain a $3 million dollar bulk export license from BIS for military aircraft parts.
Russian Sanctions Evaluation and Export Compliance Reviews for Pending Transactions:
Since 2017 one of our most common client phone calls has been “Can I export my [Computer, Medical Device, oil drilling equipment etc…] to my distributor or end user in Russia?” In recent months the U.S. government has been tightening the regulatory noose on the Russian government and Russian industry with ties to the Russian State. Specifically new economic sanctions imposed by both the U.S. Department of Commerce, Bureau of Industry and Security as well as the Department of the Treasury, Office of Foreign Assets Control (OFAC) has created the need for exporters to navigate a complex web of regulatory sanctions in evaluating the risk profile for potential export transactions. Over the past year, at TSI Global Consulting, we have performed “deep” Consolidated List Screens and evaluated several complex pending exports against the OFAC Russian/Ukrainian sanctions as well as Parts 736, 744 and 746 of the Export Administration Regulations (“EAR”) in order to “green light” our clients exports to Russian entities. On several occasions we have had to evaluate Red Flags and in a couple of cases we have had to reject potential transactions based on the excessive risk profiles of potential Russian partners. In most cases, we can mitigate risk to a level whereby we can green light the transaction following deep Consolidated List screening [taking the OFAC 50% Rule into account] along with extensive due diligence and use of specialized end user/end use based signed certifications
Cuba: Export Compliance and Licensing
In 2017 TSI Global Consulting was retained to advise on EAR regulations and licensing by a major hardware manufacturer that wanted to export building construction supplies to Cuba. The niche opportunity developed as a result of recent regulatory liberalization initiatives that were put into place by the waning Obama Administration which allowed for some limited exports of construction material to the private sector in Cuba as an exception to the ongoing trade embargo. We also assisted the company in navigating and ensuring compliance with the Cuban Assets Control Regulations or CACR administrated by the US Department of the Treasury, Office of Foreign Asset Controls (OFAC)
Oil and Gas Industry/Licensing:
We contracted with a $US 400 million dollar Houston, Texas based energy company to draft, file and obtain a BIS export license for export controlled nickel valves to the Saudi Arabia ARAMCO-SAMREF oil refinery. We also advised a Florida based steel and metal alloy distributor to successfully obtain an export license from the U.S. Department of Commerce, Bureau of Industry and Security (BIS) for the export of aluminum round bars (ECCN 1C202) controlled for nuclear proliferation to Mexico for processing into tools used by a Fortune 500 U.S. corporation operating in the oil and gas industry.
Working on behalf of a U.S. based exporter of raw materials we drafted, filed, and obtained a license from BIS to export $2 Million dollars of zirconium and hafnium controlled for nuclear proliferation to the Peoples Republic of China for manufacture of “getters” used as insulation for semiconductors and a wide range of commercial products. In 2017 we drafted, filed and obtained a $500,000 license on behalf of a US subsidiary of a Chinese owned company to export Hafnium for commercial end uses in China.
We advised a Singaporean based re-seller of semiconductor tooling to determine ECCN classification and licensing requirements under the U.S. Export Administration Regulations (EAR) for semiconductor tooling warehoused in the United States and scheduled for export to South Korea and Singapore.
Information Technology/Encryption Registration and Review:
We worked on behalf of a Los Angeles based manufacturer of LCD display boards to classify encryption capable microchips for export to the Peoples Republic of China. Drafted and filed an encryption registration application with the Bureau of Industry and Security through the SNAP-R system. And in 2021 we assisted and provided regulatory guidance to a New York based company to classify and export under license exception “ENC” some micro computer chips to Israel.
Crime Control Products:
We consulted a California based wholesale/retail company and successfully obtained a BIS export license to export fingerprinting dyes and inks to a distributor in Brazil for resale to the Brazilian police.
We advised on, drafted, filed and obtained from the Department of State a Commodity Jurisdiction for a Virginia based firm that designed technology used to track satellite interference location sources. And in 2020 we obtained a BIS export license for a Massachusetts based company to export commercial satellite parts to Israel.
Medical Device/OFAC Licensing:
Worked on behalf of a New England based manufacturer of medical devices to draft and file a license with the U.S. Treasury Office of Foreign Assets Control (OFAC) for export to a sanctioned country.
Machine Tools/BIS Licensing:
TSI Global Consulting has for the past five years served as the outsourced export compliance division for a major American manufacturer of CNC machine tools that are classified under ECCN 2B201 and controlled for nuclear proliferation. On behalf of this client we have drafted, filed, and obtained over ten BIS export licenses accounting for millions of dollars of CNC 5-Axis machine exports to numerous markets in the Middle East and Latin America. In mid-2017 we took on an Israeli client in the medical device industry that needed our assistance in structuring a routed export transaction and obtaining a license for their US agent in exporting a 2B201 CNC machine. And in 2020 we assisted a California based semiconductor manufacturer to license and export a 2B201 CNC machine tool to their subsidiary in Malaysia.