Parts made by more than a dozen US and Western companies were found inside a single Iranian drone downed in Ukraine last fall, according to a Ukrainian intelligence assessment. The finding underscores the importance of certifying end users and end use, even for EAR99 and other non-licensable ECCNs. Your company should be receiving a negative end use statement for all exports in which your customer certifies that the items will not be transferred or reexported to sanctioned parties or destinations. Such certification can help to keep items out of the hands of hostile forces as well as avoiding negative publicity if, and when, the manufacturer or exporter of the items illicitly transferred is revealed. Please contact our office and we can assist you in ensuring you are receiving the proper certification from your customers.
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.