EAR, ECCN, ITAR, License Exceptions
On the Commerce Control List (CCL), items controlled in the 600 series (those with a “6” as the third character of the ECCN) are military items, most of which were previously controlled on the United States Munitions List (USML) and subject to the ITAR. Such sensitive...
Hardware, ITAR, License Exceptions, Software
Hardware and software that incorporates encryption is a much larger category of exports than most people realize. That’s because just about anything that contains some sort of encryption capability – even if it’s ancillary to the item’s primary function – needs to be...
CCL, ECCN, Export Controls, License Exceptions, No License Required
From the exporter’s point of view, No License Required (NLR) is the easiest and most common form of export authorization. There are no hoops to jump through, notifications to provide or exceptional record-keeping requirements. NLR applies to the vast majority of U.S....
BIS, Commerce Dept, EAR, License Exceptions, Licensing
By: Kevin J. Wolf, Esq., kwolf@akingump.com, +1 202-887-4051;Shiva Aminian, Esq., saminian@akingump.com, +1 310 552 6476; and Chris Chamberlain, cchamberlain@akingump.com, +1 202-887-4308, all of Akin Gump Strauss Hauer & Feld LLP. Key Points: The Department of...
EAR, India, License Exceptions
By: Danielle Hatch Effective August 3, 2018, the Bureau of Industry and Security (BIS) has removed India from Country Group A:6 and placed it in Country Group A:1 (Supplement No. 1 to Part 740) and Country Group A:5. In a nutshell, this change is going to expand the...