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Archive for author: Sarah Guasta

Agreement Guidelines Revised

Wilmarth and Associates - Taking Notes

DDTC has revised the Guidelines for Preparing Agreements. Go to: https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&vie...

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Foreign Direct Product Rules: Clarifications and Corrections

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BIS has issued a final rule which re-organizes, makes minor corrections, and clarifies parts of the Foreign-Direct Product Rules (FDP). The FDP, inclu...

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License Exception GOV

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License Exception GOV (§740.11) authorizes exports, re-exports, and in- country transfer of eligible items to U.S. government persons and agencies, ag...

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Information Security Controls: Delay of Effective Date

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**As of January 12, 2022, the effective date for the interim final rule published October 21, 2021, at 86 FR 58205, is delayed to March 7, 2022. Tigh...

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Happy Holidays!

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Happy Holidays from Wilmarth & Associates!  

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Cambodia Added to BIS List of Military/Military End User Controls and Department of State List of Proscribed Countries

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The Bureau of Industry and Security (BIS) has  added Cambodia to: (1) The list of countries subject to the licensing policy in § 742.4(b)(7), (2) the ...

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Automated Export System (AES) Updated Response Message for Type “C33” No License Required Filings

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Beginning January 13, 2022, AES will display a new response message for exports erroneously filed under Type “C33” No License Required. If the country...

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Voluntary Disclosures to DDTC

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At the end of November 2021 DDTC published frequently asked questions (FAQs) related to voluntary disclosures. Of particular note in the FAQs was info...

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Foreign National Employees and Green Card Status (Permanent Resident Card)

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If you have a foreign national employee who has licensing with DDTC or BIS permitting access to controlled technical data, who has acquired U.S. perma...

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Tightened Controls on Cyber Security Items

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On October 20th, BIS released an interim rule which enhanced controls on certain Cyber Security items that can be used for malicious cyber activities....

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