Export Requirements, Licensing & Compliance Sanctions & Embargo Programs

The first step in ensuring export compliance is determining which federal agency regulates the export transaction. Determining whether a license is required before a commodity, software or technology is exported saves a company both time and money. We support our clients through the submission of commodity jurisdiction and licensing requests to eliminate the guesswork when exporting from the United States.
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An effective export control system begins with an evaluation of a company's internal systems, processes and procedures. We work with our clients in assessing their current level of compliance and recommending improvements where necessary.
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While some companies only require improvements in their existing internal control system, for others, it is necessary to build a comprehensive export management system from the ground up. For those clients, we work with the key functional areas throughout the organization to target control points, develop policies and procedures, implement screening tools and establish a program of on-going review consistent with governing agency expectations.
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Companies involved in the development, production or marketing of ITAR-controlled goods, technologies or services oftentimes are required to share their technology, manufacturing know-how or other controlled intellectual property. In those instances, we work with our clients to identify when and where Technology Assistance or Manufacturing License Agreements are required and to secure licenses from the DDTC as required. We also support our clients in the drafting and execution of these Agreements consistent with all export control requirements.
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Perhaps no areas have received a greater level of attention by the export control agencies than deemed exports and the re-exportation of U.S. origin goods and technology. We perform reviews of companies' global operations to identify potential risk areas, establish procedures for compliance with deemed export/re-export obligations, and secure export licenses in support of these operations as warranted.
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The Anti-Boycott provisions of the Export Administration Regulations present a unique risk to companies engaged in global trade. Adherence to non-transparent foreign governmental requirements and expectations, as well as the terms contained in letters of credit, requests for quotes, purchase orders and shipping documentation, without regard to U.S. legal obligations can lead to the imposition of significant penalties and adverse publicity. We counsel our clients on Anti-Boycott compliance so that they may ethically compete in the global marketplace while complying with all reporting and transaction verification processes.
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The extraterritorial reach of U.S. export controls requires ensuring that not only U.S. locations and personnel are familiar with U.S. legal requirements, but also that foreign locations, suppliers and customers are likewise educated. We develop comprehensive training programs tailored to both our clients' needs and their global footprint.
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The marked increase in the civil penalties imposed for violations of U.S. export laws along with the bifurcated approach adopted by the overseeing agencies in evaluating existing/historical risk increases the risk of non-compliance while further encouraging companies to review their existing export policies and self-report any violations that are found. We work with our clients to prepare voluntary self-disclosures to all affected agencies while also representing them should an investigation or penalty action be commenced.
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