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Archive for category: Blog

Restrictions On Exports, Reexports, And Transfers (In-Country) for Certain Military-Intelligence End Uses or End Users.

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Following on restrictions announced last year for military end users and end use, BIS has published a final rule, effective March 16, 2021, imposing a...

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Temporary Import License Exemption

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Temporary Import License Exemption 22CFR 123.4(a)(1) of the ITAR allows for the temporary import (and subsequent export) without a license, for a peri...

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International Traffic in Arms Regulations: Addition of Russia

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International Traffic in Arms Regulations: Addition of Russia On March 1, 2021, the Secretary of State determined pursuant to Section 306(a) of the Ch...

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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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This Blog is made available by Wilmarth & Associates for educational purposes as well as to give you general information and a general understanding of export law and compliance, not to provide specific legal advice. This blog is not legal advice and should not be treated as such. You must not rely on this blog as an alternative to legal advice from your attorney or other professional legal services provider. The information provided on this website is presented “as is” without any representations or warranties, express or implied.
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