January 2011

February 1, 2011 | Permalink
BIS recently released an advisory opinion on cloud computing that clarifies the deemed export rule for service providers. The original request was submitted in March 2010 and illustrates the difficulty in addressing the new and evolving methods of shared computing. read more
February 1, 2011 | Permalink
On January 25, 2011 BIS published a revision to the EAR to remove a number of Indian entities from the Entity List. The listing required companies to obtain an export license prior to export, re-export or transfer of certain U.S. origin items to the listed entities. read more
January 26, 2011 | Permalink
BIS recently released its annual report to Congress summarizing BIS’ activities over the past fiscal year. The FY 2010 Annual Report, covering activities from October 1, 2009 through September 30, 2010, discusses an array of topics, including regulatory developments, export licensing and export enforcement. The report can be especially helpful when pulling together information that you may need when presenting to company executives or others who want insight into agency actions.
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January 21, 2011 | Permalink
Last week we touched on a number of clarifications provided by Commerce Department officials during our webinar. In the event you were not able to attend the webinar, you may view the slides and listen to audio here... read more
January 13, 2011 | Permalink
On Thursday we held a webinar -- a Part II of a deemed export series -- which included Assistant Secretary Kevin Wolf and other key BIS officials. Commerce addressed a number of key areas pertaining to deemed exports and the new I-129 export control certification.
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January 12, 2011 | Permalink
On Thursday we will host Part II of a webinar series on deemed export compliance and, more specifically, what an organization should do to ensure it is in a position to complete the new Form I-129 Petition for Nonimmigrant Worker export control certification. read more
January 11, 2011 | Permalink
In addition to metrics, another important aspect of compliance programs is checking the health of the programs through self reviews and audits. A recent BIS case mandated that PPG Industries, Inc. complete two external audits in compliance with their Settlement Agreement. Although PPG Industries is also required to pay the maximum civil fine, an audit is a common requirement in many BIS and DDTC cases.
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January 10, 2011 | Permalink
Invariably there comes a time (perhaps too often for some) when every export compliance professional must answer the question “What is it that you do?” I imagine that most can answer that question fairly quickly but the real question is: Can you answer that question with real and substantive data? read more
January 6, 2011 | Permalink
Many times we've seen companies do the required upfront work to register with the State Department as a broker only to forget that an annual brokering report must be submitted by January 31 of each year. This is a gentle reminder to those registered as an ITAR broker to submit the required report, which is detailed in ITAR Section 129.9. read more
January 5, 2011 | Permalink
Next Thursday, January 13 we will provide a free webinar on the topic of the new I-129, Part 6 export control certification. This represents Part II of a series on the new I-129 export control certification. During the first webinar, we discussed the export control certification, how to determine if your organization requires an export license to release technologies to foreign national workers, potential immigration and export control implications, and best practices. read more