EPCI-Enhanced Proliferation Control Initiative
Along with the recent end user/end user regulations enacted by BIS over the last year, we want to highlight the Enhanced Proliferation Control Initiative (EPCI) which controls the export of all items, including EAR99, for certain nuclear and missile end use.
Under the Export Administration Regulations (EAR), a license is required to export/reexport ANY item subject to the EAR if you know the item may be used in missiles or UAVs:
– With a range greater than or equal to 300km in or by D:4 countries
– Capable of WMD delivery
– Missiles/UAVs of indeterminate capability or end use in or by D:4 countries
D:4 Countries include: Bahrain, China, Egypt, Iran, Iraq, Israel, Jordan, North Korea, Kuwait, Lebanon, Libya, Macau, Oman, Pakistan, Qatar, Russia, Saudi Arabia, Syria, United Arab Emirates, Venezuela and Yemen.
A license is also required for any item subject to the EAR if you know or are informed by BIS that the item may be used in:
– Nuclear explosive activities
– Certain unsafeguarded nuclear activities
– Certain fuel cycle activities whether or not subject to the IAEA safeguards
Licenses for these items and end uses will be reviewed on a case-by-case basis.
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.
