Technology Controls, Part III: Definition of "Required" March 12, 2019 We're back with Part III of our blog series in understanding “technology” controlled under the [...]

Heightened Scrutiny for "Emerging" Technologies November 21, 2018 This week the Bureau of Industry and Security (BIS) published an advance notice of proposed rulemaking (ANPRM) seeking comments [...]

Using National Stock Numbers for Commodity Classification July 19, 2018 Compliance practitioners know that commodity classifications are the essential first step in determining export control [...]

Smoking Hot: Proposed Changes to USML Categories I, II, and III May 15, 2018 On top of the background buzz regarding the ZTE zigzag, the [...]

OFAC Tries the Carrot and the Stick Approach with Russian Aluminum Giant April 23, 2018 In case you missed the flurry of Russian sanctions news [...]

Jurisdiction, Classification and Licensing: A Primer February 22, 2018 Export control can be baffling to newcomers. It is a blizzard of acronyms, “defined terms,” and [...]

"Capable of" Confusion February 22, 2018 “Capable of” is a confusing phrase in the vernacular of the Commerce Control List (CCL). Before I explain, let [...]

“Technology” – Part II: Development, Production, & Use January 22, 2018 Happy New Year, folks! I’ve kept you in suspense long enough, so here it [...]

Thinking About Investing in Petro? Not If You Don’t Want OFAC On Your Case January 22, 2018 Unfamiliar with the “petro?” You’re likely not alone [...]