When I started my career in trade compliance in 1990, our friends and foes were discussed in terms of “COCOM” – Coordinating Committee for Multilateral Export Controls. COCOM was an established group of “western bloc” member states and cooperating countries whose mission was to enact an embargo on “eastern bloc” countries (mainly Russia). During this…
December 1989. Dresden, East Germany. The Berlin Wall has fallen, heralding the end of the Cold War. A surge of pro-democracy sentiment sweeps through Eastern Europe. One fateful night in December, a crowd of demonstrators tries to storm a nondescript building known to be the East German headquarters of the KGB. Rushing outside, a panicked,…
If you made a list of corporations that you’d never want to battle in court, which one would be at the top of that list? Perhaps one with $200 billion in cash? Maybe one with a market cap of $2.8 trillion and the second-most valuable brand in the world? Last month, a small Israeli company…
Appropriate to the Season and to something that should stay with us all throughout the year… On the first day of Christmas my company gave to me- A Management Compliance Policy which establishes my management’s and my company’s commitment to export compliance; On the second day of Christmas my company gave to me- An Export…
The U.S. Department of Commerce announced sanctions against twenty-eight Chinese governmental and commercial organizations for engaging in or enabling activities contrary to the foreign policy interests of the United States, by adding these organizations to the Entity List. Eight of the entities are companies and the remaining twenty are municipal and county public security bureaus…
In a previous blog, we discussed the concept of “reasonable care” as it applies to your trade compliance program. The focus was how export and import programs dovetail with many other areas of compliance, such as policies and procedures, valuation, Free Trade Agreements, and more. Today, I’d like to switch gears and talk about how…
Ever wonder why your license application is taking so long to be reviewed and approved? Many thoughts go through a Compliance Officer’s mind when the license process is taking longer than expected: “Did I make a mistake on the license application?” “Should I have provided more information?” “Did I miss something in my due diligence?”…
If you’ve spent any time in trade compliance, you’ve probably come across the term “reasonable care.” But what, exactly, does that mean? The ambiguous nature of this phrase has caused many different interpretations over the years. Let’s review some practical ways to apply this principle to your global trade compliance program. The idea of “reasonable…
One of the controls the U.S. government places on export activity is the Denied Parties Lists (also sometimes referred to as Restricted Parties Lists or RPL). These lists consist of both foreign and U.S. parties that are prohibited by varying degrees from engaging with U.S. businesses. Anyone questioning the importance of a denied parties screening…
Earlier this month, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) denied export privileges for two individuals and three companies. The actions center around a conspiracy to illegally export web-monitoring and controlling equipment and software to Syria. In particular, this conspiracy involved the Syrian Telecommunications Establishment (STE). “The settlement announced today results…