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.
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.