Consultants Corner

Honeywell International, Inc. Reaches 3 Year Consent Agreement With the Department of State

By Jenny Hahn, President The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) has announced that Honeywell International, Inc. has entered into a 3 year Consent Agreement to resolve charges that it committed 34 violations of the Arms Export Control Act and the ITAR between July 2011 and July 2018 involving unauthorized exports …

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To Register or Not, That Is The Question

By Jenny Hahn, President Do I need to register or maintain registration with the Department of State (“DOS”)? Companies may find themselves asking this question, as a result of Export Control Reform. There are several factors to consider before deciding that your company should or should not register or maintain its registration with the Department …

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DDTC wants to know about your compliance program.

By Odyssey E. Gray, III & Jenny Hahn Senior Licensing Associate & President The Defense Directorate of Trade Controls (“DDTC”) has completed its IT Modernization with the implementation of the Defense Export Control and Compliance System (“DECCS”) in February 2020. Users will see that DDTC updated the DS-2032 Registration form in several aspects, moving information …

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Do You Know Where Your Export Controlled Technical Data Is?

By Jenny Hahn President FD Associates, Inc. In today’s global environment, the transfer of export controlled technical data, your company’s IP or customer technical data occurs in an instant. Export controlled technical data is regularly transferred electronically by email or other means to domestic and international customers, partners, vendors, legal counsel and consultants. To ensure …

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Due Diligence Considerations When Exporting to China

by Keil J. Ritterpusch Senior Compliance Associate and Jenny A. Hahn President The current climate between the U.S. Government and China related to export-controlled commodities is quite hostile and is not likely to change in the near term, even with a new U.S. President in place.  The U.S. Government, concerned with national security threats, human rights abuses, military modernization, theft …

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The President Signs Executive Order to Treat Hong Kong as China

By: Carlos Bentancor, Junior Associate & Jenny Hahn, President Hong Kong Now an Arms Embargoed Destination Announced 7.14.2020 and License Exceptions for EAR Items are Suspended The President signed an Executive Order (EO) on July 14, 2020, which requires the Special Administrative Region of Hong Kong (Hong Kong) to be treated as the People’s Republic of …

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US Department of Commerce Publishes Rules that Greatly Expand the Requirement for Obtaining EAR Licenses and Filing EEI for Exports of Products Destined for China, Russia, and Venezuela

By:  Keil J. Ritterpusch, Senior Compliance Associate, and Jenny Hahn, President On April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry & Security (“BIS”) published two new final rules and one proposed rule to the Export Administration Regulations (“EAR”) which substantially affect U.S. exporters of goods to China, Russia, and Venezuela.  In general, …

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DDTC ANNOUNCES NEW POLICIES AND CHANGES AFFECTING ITAR REGISTRATIONS, LICENSING, PART 130 REPORTING, AND DDTC MANAGEMENT

COVID 19 has impacted our daily lives. DDTC is no exception. Between the DECCS rollout and COVID 19 telework, DDTC is impacted and has responded with the following policies and changes intended to aid industry and ease the burden on exporters that may be hampered during this period to make filings in accordance with the …

DDTC ANNOUNCES NEW POLICIES AND CHANGES AFFECTING ITAR REGISTRATIONS, LICENSING, PART 130 REPORTING, AND DDTC MANAGEMENT Read More »

DECCS Is Here!

Don’t Panic, Just Enroll If you are registered as an exporter or manufacturer of defense articles with the Department of State, Directorate of Defense Trade Controls (“DDTC”), you have by now probably noted reference to “DECCS”, the Defense Export Control and Compliance System, either on the DDTC website or in correspondence from or with DDTC.  Do …

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