Compliance practitioners know that commodity classifications are the essential first step in determining export control requirements, responsibilities and risks. However, in situations where the exporter is not the original manufacturer of an item or specific product specifications are unavailable, making an export classification determination can be difficult. One valuable and often overlooked piece of information is the National Stock Number (NSN) but it must be used with caution.
On top of the background buzz regarding the ZTE zigzag, the latest shoe has dropped in the ongoing export control reforms. Three shoes actually, since we can now read about the proposed move of certain items controlled in Categories I, II, and III on the U.S. Munitions List (USML) over to the Commerce Control List (CCL). Long awaited by U.S. gun and ammunition manufacturers and exporters, these proposed rules describe how articles the President determines no longer warrant control under USML would be controlled on the CCL and by the Export Administration Regulations (EAR) and describe more precisely articles warranting export and temporary import control on the USML.
CTP is pleased to announce the appointment of Sean McDevitt to serve as the Director for our newly formed Digital Services Group (DSG). The DSG group will build upon CTP’s established online and digital services capacity to meet the needs of an evolving market place. Sean will apply his 20 years of website production, user experience, and media expertise to help CTP deliver high quality eLearning, online engagement, and 508 compliance services.
Topics: News & Noteworthy
In case you missed the flurry of Russian sanctions news over the past few weeks, you may have missed an addition to the sanctions that could impact your business, especially if you’re in the aluminum market. On April 6, 2018, the Treasury Department’s Office of Foreign Assets Control (OFAC) added a number of prominent Russian individuals and entities, including Russian government officials, to its Specially Designated Nationals and Blocked Persons List (SDN List). Among those was the designation of Russian oligarch, Oleg Deripaska. If the name doesn’t sound familiar to you, the aluminum magnate is tied up in allegations regarding interactions with former Trump campaign chairman, Paul Manafort, related to the 2016 presidential election.
Export control can be baffling to newcomers. It is a blizzard of acronyms, “defined terms,” and citations. In our compliance practice, we often have to lay out the basics for new clients in order to even discuss their situation. Many others know bits and pieces but don’t see how the puzzle fits together. So to any compliance veteran reading this, go no further. What follows is a primer, plain and simple.