On August 19th, BIS published a final rule with corrections and clarifications regarding the control of firearms subject to the EAR. https://www.govinfo.gov/content/pkg/FR-2021-08-19/pdf/2021-17647.pdf. The final rule will be effective September 20, 2021.
Notable among the corrections and clarifications is the requirement to have a valid International Import Certificate (IIC) on file prior to the export of ECCNs 0A501 and 0A505 and that all future license approvals will contain a rider requiring that a valid IIC be on file. International Import Certificates for OAS countries typically have a one-year validity while BIS licenses are valid for 4 years. As such, in the future exporters will need to obtain and upload updated IICs to the license on a yearly basis.
Please contact our office if you have any questions or concerns regarding these changes in regulations.
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