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Do’s and Don’ts of Filing a Commodity Jurisdiction Request

An Introduction to Export Controls

Over 95% of the world’s consumers are outside of the United States. Opportunities abound for U.S. companies that export. However, exporting is a privilege and not a right. U.S. exporters have an important responsibility to adhere to U.S. export control laws, including the Export Administration Regulations (“EAR”), and the International Traffic in Arms Regulations (“ITAR”). Violations of export control laws carry hefty civil and criminal penalties. Exporters can pay hundreds of thousands of dollars in penalties, lose export privileges, and even be imprisoned for violations of U.S. export control laws.

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By Jennifer Diaz|2022-07-08T09:43:44-04:00June 22, 2021|China, Cuba, EAR, Enforcement, Export, International Trade, Iran, ITAR, U.S. Bureau of Industry and Security (BIS), U.S. Directorate of Defense Trade Controls (DDTC), U.S. Office of Foreign Assets Control (OFAC)|2 Comments

OFAC Sanctions & Licensing

Co-Authored by Sharath Patil

Background on U.S. Sanctions (as of May, 2021)

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) administers a number of different sanctions programs. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. Currently, OFAC administers 35 sanctions programs. These sanctions programs vary widely – some are comprehensive while others are highly selective.

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By Jennifer Diaz|2022-07-08T09:40:36-04:00June 1, 2021|China, Cuba, Export, International Trade, Iran, U.S. Department of Commerce (DOC), U.S. Office of Foreign Assets Control (OFAC)|2 Comments

Building a Strong Export Compliance Plan

Co-Authored by Sharath Patil

Exporting is a Privilege, Not a Right

Over 95% of the world’s consumers are outside of the United States. Opportunities abound for U.S. companies that export. However, exporting is a privilege and not a right. U.S. exporters have an important responsibility to adhere to U.S. export control laws, including the Export Administration Regulations (“EAR”), the International Traffic in Arms Regulations (“ITAR”) the Office of Foreign Assets Control (“OFAC”) sanctions laws, and the Foreign Corrupt Practices Act (“FCPA”). Violations of export control laws carry hefty civil and criminal penalties. Exporters can pay hundreds of thousands of dollars in penalties, lose export privileges, and even be imprisoned for violations of U.S. export control laws.

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By Jennifer Diaz|2021-07-29T12:41:20-04:00February 23, 2021|Best Practices, China, China Trade War, Cuba, Customs Expert, Expert, Export, FCPA, Import, Import Alert, Iran, U.S. Bureau of Industry and Security (BIS)|7 Comments

Commerce Department Issues Rule Securing Digital Supply Chains Against Foreign Adversaries

Co-Authored by Sharath Patil

Background on Securing Information Technology & Communications Supply Chains

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By Jennifer Diaz|2022-07-07T15:07:12-04:00February 16, 2021|China, China Trade War, Cuba, Export, International Trade, Iran, Supply Chain, U.S. Bureau of Industry and Security (BIS), U.S. Department of Commerce (DOC), U.S. Office of Foreign Assets Control (OFAC)|0 Comments

Trump Administration Designates Cuba State Sponsor of Terrorism

Co-Authored by Sharath Patil

Cuba Designated a State Sponsor of Terror

The U.S. State Department designated Cuba a State Sponsor of Terrorism (“SST”) on January 11, 2021. Countries are designated on the SST list when they are determined by the U.S. Secretary of State to have repeatedly provided support for acts of international terrorism.

The four main categories of sanctions resulting from designation can include restrictions on U.S. foreign assistance; a ban on defense exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions. Here, the January 11 re-designation of Cuba on the SST subjects Cuba to:

Sanctions that penalize persons and countries engaging in certain trade with Cuba
Restricts U.S. foreign assistance to Cuba
Bans defense exports and sales to Cuba
Imposes certain controls on exports of dual use items.

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By Jennifer Diaz|2022-07-07T14:58:43-04:00January 12, 2021|Cuba, EAR, Export, Freight Forwarding, U.S. Bureau of Industry and Security (BIS), U.S. Department of State (DOS), U.S. Office of Foreign Assets Control (OFAC)|2 Comments

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