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Archive for author: Sarah Guasta

Hong Kong and China-Reminders and Updates

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As a reminder, because of ongoing Chinese threats to Hong Kong independence, Hong Kong is now treated as any other city in China. Any items that requi...

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Outside Contractors and Service Providers

Wilmart Seminar Outline

If your company uses outside service providers or contractors such as cleaning services or IT professionals, it is important to ensure that provided p...

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Export Policies and Procedures/Technology Control Plan

Wilmarth and Associates - Taking Notes

Export Policies and Procedures are an export compliance program that primarily controls sales/shipment of product but also have controls for technical...

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Commerce Amends EAR to Add Military End-User List, Removes Hong Kong as Separate Destination

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On December 23, 2020, the Commerce Department amended the EAR to add the recently released Military End-Users list, which initially includes entities ...

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Additions to the Entity List-Including Semiconductor Manufacturing International (SMIC)

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A final rule will be published in the Federal Register on December 22, 2020 adding 77 entities to the BIS Entity List. Among these are several Chinese...

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Military End-Users in China, Russia, Venezuela

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A preliminary, unpublished list was recently leaked listing 117 entities in China and Russia deemed military end users (https://www.reuters.com/articl...

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Year End Review of Compliance Requirements

2021

Training: All employees who are involved in export decision-making should receive yearly training.  Additionally, any new export involved employees sh...

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ITAR “See Through” Rule

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The phrase “see-through rule” is a colloquial phrase popularly used to refer to the impact of certain ITAR controls.  Specifically, it refers to the f...

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COMMERCE PROVIDES RELIEF FOR EXPORTERS WITH SIX-MONTH EXTENSION ON LICENSES

Wilmarth and Associates - Taking Notes

COMMERCE PROVIDES RELIEF FOR EXPORTERS WITH SIX-MONTH EXTENSION ON LICENSES New Streamlined Process Designed to Hasten Approvals Recognizing the impor...

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Update to the EAR

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The EAR has updated 10 ECCNs in response to the Wassenaur Plenary meeting. This final rule implements multilateral controls on six recently developed ...

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