As the government shutdown drags into its fourth week we, like you, are getting frustrated. Commerce export activities, most importantly BIS license applications, are not being processed. State Department matters have been severely curtailed, now operating with a small number of outside contractors. With license review being shutdown almost entirely with very few exceptions, a company might be tempted to search in between the lines for license exceptions or exemptions and bypass the licensing process altogether. Proceed with caution. While State and Commerce license reviews are at a standstill, enforcement is still robust. If you are using license exceptions or exemptions, carefully review the conditions and requirements. Make sure your copies of regulations are up-to-date. Ensure that you have properly classified the items for export and that you are using the proper exception or exemption. Don’t let frustration over the shutdown lead to a costly mistake.
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.
