Recent Department of Defense actions have established a hard line on denying commercial (ECCN 9A991 etc.) aerospace exports to China. If you export to China, it is imperative that you vet each of your end-users for possible involvement as a military end-user. The Department of Defense has taken the position that the Chinese government forces its industrial members to “share” technology with the Chinese military and that there is no way to preclude exploitation or diversion for military purposes. If your customer in China has any involvement with the Chinese military, however minor, commercial aerospace exports require a license which will be reviewed with a presumption of denial. If you have any questions regarding this policy, please contact our office.
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.