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Publications & Events (2015)

Publications, Presentations & Quotes

UN Agency Closes Investigation into Iran’s Past Nuclear Program

December 16, 2015

The Director General of the International Atomic Energy Agency (IAEA), an agency within the United Nations, recently issued a report concluding that, prior to 2003, Iran engaged in a number of activities related to the development of a nuclear explosive device. Read More→

U.S., Cuba Move to Re-establish Direct Postal Services

December 16, 2015

During discussions in Miami last week, the United States and Cuba reached an historic understanding to re-establish direct postal services between the two countries. Read More→

U.S. Helps Facilitate Trade with Burma; New General License Issued

December 14, 2015

In response to the disruption of Burmese trade due to sanctions concerns with a port in Yangon (formerly Rangoon), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a six-month general license (GL-20) in support of exports to and from Burma. Read More→

Export-Import Bank Reauthorized!

December 14, 2015

On December 4th, President Obama signed into law the reauthorization of the Export-Import Bank of the United States (EXIM Bank). EXIM Bank is the official export credit agency of the United States. Read More→

The Trans-Pacific Partnership: What Is It? What are the Benefits? And Should You Support or Oppose it?

December 3, 2015

Lately, those inside and outside the trade community have been talking about the Trans-Pacific Partnership, or TPP. But what is it? Is it good or bad? Why should the average person care? While we support free trade generally and the TPP specifically, our goal with this article is to provide you with a simplified explanation of the TPP—its scope and purpose, and to summarize the arguments that are being made by supporters and opponents alike. Read More→

AESDirect Now Available in ACE!

December 3, 2015

As of Monday, November 30, 2015, AESDirect is available for export filing in the Automated Commercial Environment (ACE). ACE Exporter Account holders can immediately begin using the new system to file their Electronic Export Information (EEI). Read More→

Liberian Sanctions Lifted!

December 3, 2015

On November 12, 2015, President Obama signed an Executive Order, terminating the Liberian sanctions program. Sanctions were originally imposed in 2004 in response to the unlawful depletion of resources and secretion of funds and other property by the former Liberian Regime of Charles Taylor. Read More→

7 Things Every Business Should Know About “Made in U.S.A.” Claims

November 11, 2015

According to an April 2013 Gallup poll, 45 percent of Americans make a special effort to purchase products made in the United States and six out of ten said they would be willing to pay more for a U.S.-made product. Read More→

BIS Introduces New Interactive Tool to Help Determine Whether a Foreign-Made Item Located Outside the U.S. is subject to the EAR

November 11, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) unveiled a new, web-based decision tool to help exporters determine whether a foreign-made product located outside of the U.S. is subject to the Export Administration Regulations (EAR). Read More→

DoD Removes Cuba from Terrorism List; Eases Restrictions for Government Contractors

November 11, 2015

On October 30, 2015, the U.S. Department of Defense (DoD) amended the Defense Federal Acquisition Regulation Supplement (DFARS), DoD’s acquisition regulations, to remove Cuba from its list of state sponsors of terrorism. Read More→

OFAC Now Permitting Transactions with Certain Belarusian SDNs

November 11, 2015

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in consultation with the U.S. Department of State, recently issued a general license authorizing U.S. persons to engage in transactions involving certain Belarusian entities designated as Specially Designated Nationals (SDNs). Read More→

House Passes Bill to Remove Ban on Crude Oil Exports

October 29, 2015

Earlier this month, the U.S. House of Representatives passed a bill that would lift the ban on crude oil exports and prohibit any federal official from imposing or enforcing a restriction on the export of crude oil. H.R. 702, introduced by Rep. Joe Barton (R-TX), would, among other things, amend the Energy Policy and Conservation Act (ECPA) to repeal its authority to restrict exports of coal, petroleum products, natural gas, and petrochemical feedstocks; as well as its restrictions on exports of certain associated equipment. Read More→

Iran Deal Goes Into Effect; U.S., Iran, Others Take Steps to Fulfill JCPOA Commitments

October 29, 2015

The Joint Comprehensive Plan of Action (JCPOA), an historic agreement between the P5+1 (the United States, Russia, China, United Kingdom, and France, plus Germany) and Iran, officially went into effect on October 18, 2015, i.e., “Adoption Day.” Read More→

OFAC Publishes Guidance on “False Hit Lists”

October 29, 2015

In maintaining sanctions screening programs, companies frequently develop “false hit lists,” which are lists of individuals and entities whose names trigger a screening match on the Specially Designated Nationals (SDN) and Blocked Persons List or other sanctions lists, but who are determined not to be SDNs or blocked persons. Read More→

Crédit Agricole Agrees to Pay Over $787 Million for U.S. Sanctions Violations

October 29, 2015

Crédit Agricole Corporate and Investment Bank (CACIB), based in France, recently agreed to pay a total of $787.3 million to state and federal agencies for violating U.S. sanctions primarily against Sudan, as well as sanctions against Burma, Iran, and Cuba. Read More→

CBP Adopts ACE as Authorized EDI System; ACS to be Phased Out

October 16, 2015

On October 13, 2015, U.S. Customs and Border Protection (CBP) issued a final rule amending its regulations to reflect that, effective November 1, 2015, the Automated Commercial Environment (ACE) will be a CBP-authorized Electronic Data Interchange (EDI) system. Read More→

ATTN: DDTC Extends Transition Period for Items Transferred from USML to CCL

October 13, 2015

On October 12, 2015, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) posted a notice extending the transition period for items transferred from the U.S. Munitions List (USML) to the Commerce Control List (CCL) pursuant to the Export Control Reform (ECR) initiative. Read More→

BIS Seeks Comments regarding Controls on Military Vehicles, Vessels, and Other Equipment

October 12, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS), on October 9, 2015, issued a Notice of Inquiry requesting public comments regarding controls on military vehicles, vessels of war, submersible vessels, oceanographic equipment, and auxiliary and miscellaneous military equipment. Read More→

USITC Commences Investigation Process to Implement Changes to HTSUS

October 12, 2015

The United States International Trade Commission (USITC) recently announced that it has begun the process of modifying the Harmonized Tariff Schedule of the United States (HTSUS) to implement the World Customs Organization’s (WCO) changes to the international Harmonized System. Read More→

President Issues Proclamation Modifying Duty-Free Treatment for Certain Articles, Countries under GSP

October 12, 2015

On October 5, 2015, the White House published Proclamation 9333 in the Federal Register, which modified duty-free treatment under the Generalized System of Preferences (GSP) for certain articles and beneficiary developing countries (BDCs). Read More→

Two Companies Doing Business in State of Texas Fined for Alleged Antiboycott Violations

October 12, 2015

Vinmar International, Ltd. (VIL), a global marketer and distributor of petrochemical products, and its affiliate, Vinmar Overseas, Ltd. (VOL), both foreign concerns doing business in the State of Texas, agreed to settle alleged antiboycott violations with the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for $19,800 and $41,400, respectively. Read More→

How the Upcoming Changes to ACE, AES, and AESDirect Will Affect Your Company!

October 5, 2015

On February 19, 2014, President Obama issued Executive Order 13659, mandating the complete development and government-wide utilization of the International Trade Data System (ITDS) to streamline the import and export process. Read More→

Lao PDR, New Zealand Ratify WTO’s Trade Facilitation Agreement

October 2, 2015

This week, the Lao People’s Democratic Republic and New Zealand (“Lao PDR”) became the 18th and 19th members of the World Trade Organization (WTO), respectively, to ratify the WTO’s Trade Facilitation Agreement (TFA). Read More→

BIS Orders Maryland Company to Complete Audit, Training for Allegedly Exporting Equipment to SDN

October 1, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently ordered Production Products, Inc. (“PPI”), a Maryland-based company, to perform an audit of its export controls compliance program and several of its officers to complete an export compliance training program for allegedly exporting equipment designated as EAR99 to a party listed on the Specially Designated Nationals and Blocked Persons List (SDN List). Read More→

Military Trucks Set for Export to Guatemala Seized by CBP Officers at Galveston Seaport

September 25, 2015

On September 23, 2015, U.S. Customs and Border Protection (CBP) announced that its officers at the Galveston seaport seized two military vehicles scheduled to sail to Guatemala without the required export license. Read More→

BIS Denies Export Privileges of Parties Conspiring to Illegally Export Web Monitoring Equipment

September 25, 2015

On September 21, 2015, BIS issued a press release announcing that, pursuant to the terms of a Settlement Agreement, two individuals and three companies were denied export privileges for conspiring to illegally export and reexport to Syria web monitoring and controlling equipment and software. Read More→

BIS, OFAC Implement Changes to Further Support the Cuban People

September 25, 2015

On September 21, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Export Administration Regulations (EAR) and Cuban Assets Control Regulations (CACR), respectively, to further implement the new U.S. policy towards Cuba announced by President Obama on December 17, 2014. Read More→

Justice Department Strengthens Pursuit of Individual Corporate Wrongdoers

September 18, 2015

The U.S. Department of Justice (DOJ) recently released a memorandum that provides DOJ’s federal prosecutors and civil attorneys with guidelines on how to handle individuals connected to illegal corporate misconduct, particularly corporate fraud. Read More→

BIS Fines South Carolina Company, Affiliates, and Officers $3.5 Million for EAR Violations

September 10, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently imposed a $3.5 million civil penalty on Streit USA, a company based in South Carolina, its affiliates, Streit Group and Streit Middle East, both based in the United Arab Emirates, and two corporate officers to settle charges that they violated the Export Administration Regulations (EAR) by selling U.S.-origin armored vehicles retrofitted with ballistic steel and bullet proof glass to end-users without the required reexport licenses or engaging in related prohibited conduct. Read More→

Russian Company Settles with BIS for Allegedly Reexporting Aircraft to Iran

September 10, 2015

On September 4, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it had reached a settlement agreement with Air Bashkortostan, LTD (“Air Bashkortostan”), a Russian company, for alleged violations of the Export Administration Regulations (“EAR”) occurring on or between January 7, 2009 and March 19, 2009. Read More→

State Dep’t Imposes Sanctions on Multiple Foreign Entities, Including Russian Arms Export Agency

September 4, 2015

On September 2, 2015, the U.S. Department of State imposed nonproliferation sanctions on multiple foreign persons, including Russia’s state-owned arms export agency, Rosoboronexport, for engaging in activities that warrant the imposition of measures under Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (“INKSNA”). Read More→

BIS Makes License Exception TMP Available for Certain Employer Communications Devices in Sudan

September 4, 2015

On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule correcting an error in License Exception TMP in order to make certain consumer communications devices and software eligible for temporary export and reexport to Sudan as “tools of trade.” Read More→

CBP Moves Back Mandatory Filing of Electronic Entry Summaries in ACE

September 4, 2015

On August 31, 2015, U.S. Customs and Border Protection (“CBP”) announced that, due to concerns about stakeholder readiness, it is pushing back the deadline requiring all electronic entry summaries to be filed in ACE (Automated Commercial Environment). Read More→

DDTC Posts Comments on Proposed Rule Clarifying Registration and Licensing Requirements for U.S. Persons

September 1, 2015

The U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) recently posted comments on the proposed rule that would amend the International Traffic in Arms Regulations (“ITAR”) to clarify the requirements for the registration and licensing of U.S. persons employed by foreign persons. Read More→

BIS Removes Special Comprehensive License (SCL) Authorization

August 27, 2015

On August 26, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to remove the Special Comprehensive License (“SCL”) authorization. Read More→

USTR Now Accepting Petitions for Annual GSP Product and Country Practices Review

August 27, 2015

On August 19, 2015, the Office of the United States Trade Representative (“USTR”) published a notice announcing that it is now accepting petitions to modify (1) the list of products eligible for duty-free treatment under the Generalized System of Preferences (“GSP”) and (2) the GSP status of certain beneficiary developing countries (“BDCs”) due to country practices. Read More→

Census: Exports drop, imports up in June 2015

August 27, 2015

Earlier this month, the U.S. Census Bureau released international trade data showing a 7.1% rise in the goods and services deficit, climbing to $43.8 billion in June 2015, up from $40.9 billion in May. Read More→

Tips on Resolving Common AES Fatal Errors

August 20, 2015

Electronic Export Information (“EEI”) is submitted through the Automated Export System (“AES”). After export data is filed, AES generates a response indicating whether the shipment has been accepted or rejected. Read More→

ITA Makes Huge Strides in Helping U.S. Businesses Succeed in International Markets

August 19, 2015

Last year, the United States exported goods and services valued at a combined total of $2.34 trillion. U.S. exports have become an increasingly vital part of the U.S. economy. Read More→

AESDirect Migrating to ACE This Fall

August 17, 2015

Exporters will soon be able to file Electronic Export Information (“EEI”) in AESDirect through the Automated Commercial Environment (“ACE”). Read More→

Secretary Kerry Raises American Flag in Havana, Cuba

August 14, 2015

Today, Secretary of State John Kerry raised the American flag at U.S. Embassy Havana, which re-opened July 20, 2015. This is the first time the U.S. flag has flown in Cuba in over 54 years. Secretary Kerry’s trip is a historic step towards normalizing relations with the Cuban government and people. Read More→

OFAC Posts Revised Guidance Regarding Temporary Sanctions Relief for Iran

August 12, 2015

On August 7, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published Revised Guidance and Frequently Asked Questions concerning the continuation of temporary sanctions relief for Iran under the Joint Plan of Action (“JPOA”). Read More→

Oil and Gas Field Added to Entity List to Prevent Violations of Russian Industry Sector Sanctions

August 12

On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule amending the Export Administration Regulations (“EAR”) to add Yuzhno-Kirinskoye Field, a Russian oil and gas field, to the Entity List. Read More→

OFAC Issues Crimea Sanctions Advisory Concerning Obfuscation of Information in Financial, Trade Transactions

August 4, 2015

On July 30, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Crimea Sanctions Advisory in which it highlighted practices used to circumvent sanctions on the Crimea region of Ukraine (“Crimea”) and outlined steps that U.S. persons (or those conducting business in or through the U.S.) should take to mitigate the risk of processing, or participating in, prohibited transactions. Read More→

U.S. Congress Renews and Extends Generalized System of Preferences

July 31, 2015

Effective July 29, 2015, the Generalized System of Preferences (“GSP”) program is reinstated. GSP is a preferential trade program that affords duty-free treatment to certain products entering the United States from eligible developing countries. Read More→

BIS Amends EAR to Implement Cuba’s Removal from State Sponsors of Terrorism List

July 30, 2015

On July 22, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to implement the rescission of Cuba’s designation as a State Sponsor of Terrorism. Read More→

Export Data Now Available in ACE

July 22, 2015

U.S. Customs and Border Protection (“CBP”) continues to enhance the Automated Commercial Environment (“ACE”) through the development of key trade processing features. Read More→

U.S. and partners in P5+1 reach historic deal with Iran

July 14, 2015

Today, President Obama announced that the United States and its partners in the P5+1 (United States, Russia, China, United Kingdom, and France, plus Germany) reached an historic agreement with Iran that will prevent the country from obtaining a nuclear weapon. Read More→

OFAC Issues Venezuela Sanctions Regulations

July 13, 2015

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued the Venezuela Sanctions Regulations in order to implement Executive Order 13692 (“EO 13692”) and the Venezuela Defense of Human Rights and Civil Society Act of 2014 (“the Act”). Read More→

Centers of Excellence and Expertise Assume More Trade Authority

July 2, 2015

This week U.S. Customs and Border Protection (“CBP”) announced that, effective June 29, 2015, the Directors for the Petroleum, Natural Gas & Minerals (“PNGM”) and Pharmaceuticals, Health & Chemicals (“PHC”) Centers of Excellence and Expertise (“Centers”) will begin sharing trade authority with Port Directors for post-release trade processes of entry summaries for tariff lines filed in certain Ports of Entry. Read More→

JPOA Period Extended for Seven Days to Continue Negotiations

July 1, 2015

On June 30, 2015, the P5+1 (United States, Russia, China, United Kingdom, and France, plus Germany), the European Union (“EU”), and Iran agreed to extend the term of the Joint Plan of Action (“JPOA”) seven days in order to continue negotiations to reach a long-term, comprehensive solution that will ultimately prevent Iran from developing a nuclear weapon. Read More→

Trade Promotion Authority Bill Passes Senate; Awaits President’s Signature

June 26, 2015

On June 24, 2015, the U.S. Senate passed the heavily debated Trade Promotion Authority bill and sent it to President Obama. Read More→

Export Control Reform Continues with the Removal of Certain Directed Energy Weapons and Toxicological Agents from the USML

June 25, 2015

On June 17, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued corresponding proposed rules amending the Export Administration Regulations (“EAR”) and International Traffic in Arms Regulations (“ITAR”) respectively, to transfer certain directed energy weapons and toxicological agents from the United States Munitions List (“USML”) to the Commerce Control List (“CCL”). Read More→

BIS Amends EAR to Implement Changes to Australia Group’s Control Lists

June 18, 2015

On June 16, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to implement the November 2013 Inter-sessional Decisions of the Australia Group. Read More→

OFAC Removes Cuba from Terrorism List

June 15, 2015

On June 15, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Terrorism List Governments Sanctions Regulations to remove Cuba from its list of countries supporting international terrorism. Read More→

Court of Appeals Ruling Extends Personal Liability for Import Violations; Supreme Court Denies Review

June 11, 2015

The U.S. Supreme Court recently denied a petition to review a landmark case that expands the category of persons liable for corporate Customs entry violations. Read More→

Pursuant to JPOA, State Department Outlines Limited Sanctions Relief for Iran

June 8, 2015

On June 5, 2015, the U.S. Department of State (“State Department”) published a notice detailing further sanctions relief provided to Iran in response to the Joint Plan of Action (“JPOA”) reached between the P5+1 and Iran. Read More→

Commerce, State Department Issue Proposed “Definitions” Rules

June 3, 2015

On June 3, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) and U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued separate proposed rules revising a number of definitions in the Export Administration Regulations (“EAR”), as well as revising current, and creating new, definitions in the International Traffic in Arms Regulations (“ITAR”), respectively. Read More→

Cuba No Longer Designated as State Sponsor of Terrorism

June 2, 2015

In a press release issued on May 29, 2015, the U.S. Department of State (“State Department”) announced the removal of Cuba from its list of State Sponsors of Terrorism. Read More→

State Department Seeks Comments on Proposed ECR Amendments to ITAR

May 28, 2015

On May 22, 2015, the U.S. Department of State (“State Department”) issued a proposed rule amending the International Traffic in Arms Regulations (“ITAR”) to: (1) clarify provisions concerning the export of items subject to the Export Administration Regulations (“EAR”); Read More→

Export License No Longer Required for Certain Communications Software Destined to the Crimea Region of Ukraine

May 27, 2015

On May 22, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to allow certain Internet-based communications software to be exported and reexported without a license to the Crimea region of Ukraine (“Crimea”). Read More→

BIS Amends the EAR to Reflect 2014 Changes to Wassenaar List

May 22, 2015

On May 21, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule amending the Commerce Control List (“CCL”) to reflect changes made to the Wassenaar Arrangement’s List of Dual-Use Goods and Technologies (“Wassenaar List”). Read More→

BIS Issues Proposed Rule Implementing Wassenaar Arrangement’s Export Controls for Intrusion, Surveillance Items

May 20, 2015

On May 20, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a proposed rule to amend the Export Administration Regulations (“EAR”) with regard to export controls for cybersecurity commodities, software, and technology. Read More→

Commerce Department Provides Due Diligence Guidance to Prevent Unauthorized Reexports to Russia

May 20, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently published guidance to assist U.S. exporters in preventing the transshipment or unauthorized reexport of controlled items to Russia. Read More→

GAO: US has increased flexibility in sanctioning North Korea; UN sanctions impeded

May 19, 2015

On May 13, 2015, the U.S. Government Accountability Office (“GAO”) released a report in which it concluded that while Executive Order 13687 provided the United States with greater flexibility in imposing sanctions on North Korea, sanctions imposed by the United Nations (“UN”) Security Council have been impeded by many member states’ failure to submit required reports. Read More→

Census Bureau Eliminates AES Reporting Requirements for Temporary Exports, Carnets

May 15, 2015

On May 15, 2015, the Bureau of the Census (“Census Bureau”) published a final rule amending the Foreign Trade Regulations to exempt temporary exports, including Carnets and goods imported under a Temporary Import Bond, from the Automated Export System (“AES”) filing requirement. Read More→

CBP Launches C-TPAT Exporter Entity program

May 13, 2015

U.S. Customs and Border Protection (“CBP”) recently announced that effective May 17, 2015, U.S. exporters will be eligible to participate in the Customs-Trade Partnership Against Terrorism (“C-TPAT”) Exporter Entity program. Read More→

CBP Revokes Past Rulings; Reclassifies Certain Transporters, Chemicals, and Ornaments

May 12, 2015

On May 6, 2015, U.S. Customs and Border Protection (“CBP”) announced final and proposed revocations to certain past tariff classification rulings, as well as new corresponding classifications under the Harmonized Tariff Schedule for the United States (“HTSUS”). Read More→

Jamie Joiner Named 2015 Women Small Business Champion of the Year

May 12, 2015

Jamie Joiner has been named the 2015 Women Small Business Champion for the Houston District. The award is given annually by the U.S. Small Business Administration (“SBA”) to an individual who has shown a commitment to the advancement of women’s business ownership. Read More→

OFAC updates Ukraine-related FAQs

May 8, 2015

On May 7, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated its Frequently Asked Questions (“FAQs”) regarding the Ukraine-related sanctions. Read More→

Commerce Department Announces New Cuba Call-in Program

May 7, 2015

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently announced that it will host a monthly call-in program to address questions concerning the new Cuba rule. Read More→

Joiner Law Firm Welcomes New Senior Counsel Thomas Ludwig

May 7, 2015

We are pleased to announce the addition of Thomas Ludwig to our team of attorneys. Tom joins the firm as Senior Counsel. Read More→

OFAC Publishes New Guidance on U.S.-Cuba Travel

May 6, 2015

On May 5, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the travel provisions of the Cuban Assets Control Regulations (“CACR”). Read More→

Export Control Reform Continues with Proposed Changes to Thermal Imaging and Night Vision Controls

May 6, 2015

On May 5, 2015, the U.S. Department of State (“State Department”) and U.S. Department of Commerce (“Commerce Department”) proposed to amend the International Traffic in Arms Regulations (“ITAR”) and Export Administration Regulations (“EAR”) respectively, in order to transfer certain thermal imaging, night vision, and guidance and control commodities from Category XII of the U.S. Munitions List (“USML”) to analogous Export Control Classification Numbers (“ECCNs”) on the Commerce Control List (“CCL”). Read More→

BNP Paribas to Pay Record $8.9 Billion for U.S. Sanctions Violations; Victims may receive compensation

May 4, 2015

On May 1, 2015, a U.S. district court judge sentenced BNP Paribas SA (“BNP Paribas”) to a five-year period of probation, and ordered it to pay a total of $8.9 billion for violating U.S. sanctions against Sudan, Cuba, and Iran. Read More→

Commerce Department Implements New Initiative for Companies, Organizations Interested in Trade Missions

May 1, 2015

On April 28, 2015, the U.S. Department of Commerce’s International Trade Administration (“ITA”) established the Ready Applicant Pool (“RAP”)--an initiative for business community members interested in receiving information regarding upcoming trade missions. Read More→

Jamie Joiner to present at OTC 2015

April 30, 2015

On May 4, 2015, Jamie Joiner will present, “The District Export Councils (DECs): A Resource for U.S.C.S. Trade Professionals and Their Clients,” at the Offshore Technology Conference (OTC) in Houston, Texas. OTC 2015 will take place May 4-7 at NRG Park.

North Carolina Company Agrees to Pay $25,200 for Alleged Antiboycott Violations

April 29, 2015

On April 21, 2015, Morex, Inc. (“Morex”), a North Carolina company, agreed to pay the U.S. Department of Commerce’s Bureau of Industry and Security $25,200 for allegedly violating the antiboycott provisions of the Export Administration Regulations (“EAR”). Read More→

Two Chinese Nationals Sentenced to 24, 18 Months for Conspiring to Illegally Export Military-Related Sensors

April 27, 2015

On April 23, 2015, a U.S. District Court judge in New Mexico sentenced two Chinese nationals to federal prison for conspiring to illegally export defense-related sensors to the People’s Republic of China, in violation of the Arms Export Control Act and the International Traffic in Arms Regulations (“ITAR”). Read More→

DDTC Will Soon Deactivate Current Electronic System Used to Track Paper Applications

April 27, 2015

On April 23, 2015, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) notified the public of its intention to decommission the legacy system, Ellie Net, which currently allows Industry users to track their paper applications. Read More→

U.S. Senate, House Committee Leaders Introduce Bill to Promote Trade with Developing Countries

April 27, 2015

On April 16, 2015, committee leaders in the U.S. Senate and U.S House of Representatives introduced a bi-partisan bill to renew and enhance certain trade preference programs. Read More→

CBP Deploys New ACE Capabilities Impacting the Trade Community

April 23, 2015

On April 18, 2015, U.S. Customs and Border Protection (CBP) announced new features in ACE. The deployment is part of a series of roll-outs designed to enhance trade processing capabilities in the Automated Commercial Environment (ACE) and retire corresponding features in legacy systems. Read More→

Eight Added to Entity List for Sending U.S.-origin Items to Iran

April 23, 2015

On April 23, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to add eight individuals and companies to the Entity List. Read More→

OFAC Posts New and Updated Cuba FAQs

April 23, 2015

On April 16, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued new and updated Frequently Asked Questions (“FAQs”) regarding the recent changes to the Cuban Assets Control Regulations (“CACR”). Read More→

Justice Department: Four Corporations, Five Individuals Indicted for Illegally Exporting Technology to Iran

April 22, 2015

A federal indictment was unsealed on April 17, 2015, charging four companies and five individuals with violating the International Emergency Economic Powers Act (“IEEPA”) by illegally exporting various high-tech commodities to Iran. Read More→

State Department Issues Notice on Temporary & Limited Sanctions Relief Provided to Iran

April 22, 2015

On April 16, 2015, the U.S Department of State (“State Department”) announced a limited range of sanctions relief provided to Iran under the National Defense Authorization Act for Fiscal Year 2012 (“NDAA”). Read More→

OFAC Issues New General License for Certain Publishing Activities Involving Syria

April 21, 2015

On April 13, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Syrian Sanctions Regulations to authorize certain transactions related to publishing. Read More→

Tentative Agreement with Iran on Nuclear Program may Result in Lifting of US and EU Sanctions: No Change Just Yet

April 8, 2015

On April 2, 2015, the United States, Russia, China, France, the UK, Germany, and Iran (the P5+1 countries) announced that they have reached an agreement on the key parameters for a Joint Comprehensive Plan of Action (JCPOA) regarding the Iran nuclear program. The parties will meet through June 30, 2015, in order to confirm the details of the JCPOA in writing. Read More→

AMA United Group and its Partners Plead Guilty to Export Violations

April 8, 2015

According to the Department of Justice (“DOJ”) press release published on April 1, 2015, AMA United Group, an Egyptian procurement agent, has agreed to enter a guilty plea for violating the Arms Export Control Act. Read More→

Executive Order: Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities

April 8, 2015

On April 1, 2015, the President issued an Executive Order authorizing the imposition of sanctions on individuals or entities that engage in significant malicious cyber-enabled activities against the United States. Read More→

Schlumberger Subsidiary Pleads Guilty and Agrees to Pay $232.7 Million for Violating U.S. Sanctions by Facilitating Trade with Iran and Sudan

March 26, 2015

According to the Department of Justice (“DOJ”) press release, on March 25, 2015, Schlumberger Oilfield Holdings Ltd. (“Schlumberger”), a wholly owned subsidiary of Schlumberger Ltd., has agreed to enter a guilty plea and to pay $232.7 million in forfeiture and criminal penalties for facilitating illegal transactions and engaging in trade with Iran and Sudan. Read More→

Californian Businessman and His Company Indicted for Smuggling Sophisticated Electrical Components to Russia

March 26, 2015

On March 19, 2015, the U.S. Department of Justice announced charges against Pavel Semenovich Flider, a Russian émigré, and his San Francisco-based electronics company for smuggling sophisticated electronics out of the United States in violation of U.S. export law. Read More→

PayPal Agrees to Settle Sanctions Claims for $7.6 Million

March 25, 2015

On March 23, 2015, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) entered into a $7,658,300 settlement agreement with PayPal, Inc. to avoid potential civil liability related to 486 apparent violations of several sets of sanctions regulations. Read More→

BIS Revises Document Requirements for Export License Applications

March 23, 2015

On March 13, 2015, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a final rule to change the support document requirements for license applications under the Export Administration Regulations (“EAR”). Read More→

Commerzbank Settles Iranian Transaction Allegations for $258 million

March 16, 2015

On March 12, 2015, the Office of Foreign Assets Control (“OFAC”) announced that German Commerzbank would pay $258 million to settle allegations related to financial transactions with Iran and other sanctioned countries. Read More→

U.S. Exports Support Record 11.7 Million Jobs

March 6, 2015

On March 4, 2015, the U.S. Department of Commerce’s International Trade Administration (“ITA”) announced that U.S. exports supported a record 11.7 million jobs in 2014. Read More→

President Obama: Situation in Ukraine Continues to Pose Threat to U.S.

March 5, 2015

On March 3, 2015, President Obama issued a notice continuing the national emergency regarding Ukraine, due to the ongoing threat posed by Russia’s involvement in the Crimea region. Read More→

BIS Expands Validated End-User Authorization for Samsung China

March 5, 2015

On March 5, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to expand the validated end-user authorization of Samsung China. Read More→

President Obama Continues the National Emergency With Respect to Cuba

March 2, 2015

On February 25, 2015, President Obama announced the continuation of the national emergency with respect to Cuba. Read More→

BIS Requests Public Comment for Review of Controls regarding Military Aircraft, Gas Turbines

March 2, 2015

Today, BIS issued a notice requesting public comments to perform its review of export controls regarding military aircraft, military gas turbines, and related commodities. Read More→

Secretary of State Issues Determination Regarding Iran Sanctions

March 2, 2015

On February 26, 2015, the U.S. Department of State notified the public of several countries that had significantly reduced their crude oil purchases from Iran. Read More→

BIS Amends the EAR: Eleven Names Added to the Entity List

February 25, 2015

On February 18, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add eleven entities to the Entity List. The amendment also removed one entity. Read More→

CBP and EPA Seize and Reexport Hundreds of Vehicles, Engines Imported in Violation of the Clean Air Act

February 24, 2015

On February 19, 2015, U.S. Customs and Border Protection, in conjunction with the U.S Environmental Protection Agency, announced that hundreds of vehicles and engines were either seized or reexported for failing to comply with federal emission standards. Read More→

BIS Revises Licensing Policy and Requirements for Communications Equipment to Sudan

February 23, 2015

On February 18, 2015, BIS revised its export controls for Sudan. The new changes removed the general policy of denial for telecommunications equipment, revised the availability of License Exception CCD, and removed the license requirement for reexports of certain telecommunications software. Read More→

State Department Announces New U.S. Export Policy for Military Drones

February 20, 2015

On February 17, 2015, the U.S. Department of State announced a new export policy for military drones, and imposed additional requirements and conditions on the sales and transfers of such. Read More→

OFAC Issues Amended General License for Personal Communications Exports to Sudan

February 19, 2015

On February 18, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued a general license for exports to Sudan of certain software, hardware, and services incident to personal communications. Read More→

State Department Lists Goods and Services Now Available for Import from Cuba

February 18, 2015

On February 13, 2015, the U.S. Department of State published a list of goods and services that may now be imported from Cuba. Read More→

Three Importers Settle to Pay Over $3 Million for Evading Customs Duties

February 16, 2015

On February 12, 2015, the U.S. Department of Justice (“DOJ”) announced that three importers agreed to pay over $3 million for allegedly evading customs (antidumping and countervailing) duties on aluminum extrusions imported from China. Read More→

Industrial Equipment Wholesaler Denied Export Privileges for Violations of U.S. Sanctions

February 16, 2015

On February 12, 2015, BIS denied the export privileges of Maple Pacific. Maple Pacific was recently convicted of violating federal law by exporting industrial parts to Iran without a license or authorization. Read More→

Lawmakers Push for Tougher Sanctions on North Korea

February 12, 2015

On February 5, 2015, prompted by the recent cyber-attack against Sony Pictures, lawmakers introduced legislation to toughen U.S. sanctions on North Korea. Read More→

Judge Rejects Fokker’s $10.5 million Settlement for Violations of U.S. Sanctions

February 10, 2015

On February 5, 2015, a U.S. District Court rejected the $10.5 million settlement between the U.S. and Fokker Services, BV, issued as part of a deferred prosecutorial agreement for Fokker's unlawful exports of U.S.-origin aircraft parts, technology, and services to Iran, Sudan, and Burma. Read More→

OFAC Blocks Property of Seven Additional Entities

February 9, 2015

On February 6, 2015, OFAC added the names of seven entities whose property and interests in property were blocked pursuant to Executive Order 13660, “Blocking Property of Certain Persons Contributing to the Situation in Ukraine.” The names of seventeen individuals were also added. Read More→

New FTR Rule Assists Federal Agencies in Accessing Electronic Export Information

February 9, 2015

Census Bureau amended the Foreign Trade Regulations (FTR) to clarify confidentiality provisions related to the use of Electronic Export Information (EEI) and facilitate the legitimate sharing of export data amongst federal agencies, consistent with the purpose of the International Trade Data System (ITDS). Read More→

BIS Removes License Requirement for Certain Controlled Items sent to India

December 16, 2015

On January 23, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove license requirements for certain items controlled for crime control and regional stability reasons with respect to India. Specifically, BIS removed India from Crime Controls (CC) columns 1 and 3, and Regional Stability (RS) column 2 of the Commerce Country Chart. Read More→

Electronic Protest Information Now Available in ACE Reports

February 5, 2015

U.S. Customs and Border Protection (CBP) recently added features in the Automated Commercial Environment (ACE) to make electronic protest information available in ACE Reports. The features provide brokers and importers the ability to obtain the status of an electronic protest filed for an ACE Entry Summary via the Automated Broker Interface (ABI). Users can now modify Entry Summary Management (ESM) reports to receive these updates. Read More→

OFAC Issues Additional Licenses for Crimea region of Ukraine

February 4, 2015

On January 30, 2015, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published three general licenses related to Executive Order 13685--which blocked property and prohibited specified transactions involving the Crimea region of Ukraine. Executive Order 13685 was issued on December 19, 2014 in response to Russian occupation of Crimea. The recently issued OFAC licenses authorize certain activities and transactions that would otherwise be banned by the order. Read More→

BIS Imposes New License Requirement for Crimea Region of Ukraine

February 3, 2015

On January 29, 2015, in furtherance of U.S. policy toward Russia, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to require a license for exports and reexports to the Crimea region of Ukraine, and transfers within the region. The rule applies to all items subject to the EAR, with the exception of food and medicine designated as EAR99, and imposes a presumption of denial for license applications submitted for exports, reexports, and transfers to the region. Read More→

BIS and OFAC Implement Changes to U.S.-Cuba Relations

January 21, 2015

On January 16, 2015, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) and the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued Final Rules to amend the Cuban Assets Control Regulations (CACR) and the Export Administration Regulations (EAR). These amendments to the CACR and EAR will implement changes to U.S-Cuba relations announced by President Obama on December 17, 2014. Read More→

Providing Support for the Cuban People

January 15, 2015

Today, the Federal Register posted Commerce and Treasury rules implementing the President’s new Cuba policy announced on December 17, 2014. Deputy Assistant Secretary for Export Administration Matthew Borman and Anthony Christino, Director of the Foreign Policy Division, Office of Nonproliferation & Treaty Compliance, Bureau of Industry and Security, U.S. Department of Commerce, will be discussing these changes and answering your written questions in a teleconference on January 21 at 2:30 p.m. Read More→

Past Events (2015)

Below are Joiner Law Firm related events of 2015:

NOV17 Foreign Exchange, Export Controls & The Department of Commerce

Join the Houston DEC for a breakfast and networking event designed to teach you best practices for success in your export business. Darrell Spires, Director of Joiner Trade Solutions, will present on export licensing requirements. Other speakers will discuss how to protect your business against foreign exchange risk and provide you with an overview of the U.S. & foreign commercial service. The event will be held at the Spring Branch campus of Houston Community College. Link


APR30 Jamie Joiner to present at OTC 2015

On May 4, 2015, Jamie Joiner will present, “The District Export Councils (DECs): A Resource for U.S.C.S. Trade Professionals and Their Clients,” at the Offshore Technology Conference (OTC) in Houston, Texas. OTC 2015 will take place May 4-7 at NRG Park.


FEB19 Advancing Global Markets TV-Radio Show 2015 Networking Launch Reception Presents The 10th Annual Export Control Forum

Jamie Joiner to discuss the importance of emerging global markets and international trade compliance at the “Advancing Global Markets TV-Radio Show 2015 Networking Launch Reception.” The event will take place at the Hyatt Regency in Downtown Houston. Link