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The PT Law Blog

Japan Eases Military Export Control Laws, Clouds JSF Sales

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Friday, 30 December 2011 10:58

Accoring to the Australian newspaper The Canberra Times, there are concerns that Japan's recent easing of export control laws could hurt Australian defense contractors participating in the Joint Strike Fighter (JSF) program. Japan recently announced that parts Japanese companies were making in Japan for use on the JSF would be available for planes in other countries.  Follow this link to read the complete story, "Australian bids for JSF work put in jeopardy."

 

 

US Government Sanctions Maltese Entities with Ties to Iranian Shipping

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Tuesday, 20 December 2011 19:03

The U.S. government announced today that one individual and ten (10) shipping companies located in Malta have been sanctioned for having links to the Islamic Republic of Iran Shipping Lines (IRISL). IRISL is a specially designated national (SDN) under U.S. law.

Under Secretary of the Treasury for Terrorism and Financial Intelligence David S. Cohen said "[a]s IRISL and its subsidiaries continue their deceptive efforts to escape the grasp of U.S. and international sanctions, we will continue to take action—as we are today—to expose the front companies, agents and managers working with IRISL and work to stop this illicit business."

For sevearal years, "IRISL has facilitated shipments of military-related cargo destined for Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and its subordinate entities, including organizations designated by the United States for sanctions pursuant to Executive Order (E.O.) 13382 and listed in United Nations Security Council Resolutions 1737 in 2006, 1747 in 2007, and 1929 in 2010. The Department of State designated MODAFL pursuant to E.O. 13382 in October 2007, and the Treasury Department designated IRISL in September 2008," the release added. 

For more information, visit the Treasury Department website.

 

Proposed ITAR Brokering Rules Published This Week

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Tuesday, 20 December 2011 11:14

by Jason Poblete

This week the Department of State published a much anticipated proposed rule to amend Part 129 of the International Traffic in Arms Regulations (ITAR) relating to brokers and brokering activities.

According to the Federal Register notice, "[t]he proposed revisions are intended to clarify registration requirements, the scope of brokering activities, prior approval requirements and exemptions, procedures for obtaining prior approval and guidance, and reporting and record-keeping of such activities." You can download a pdf-version of the proposed regulations by following this link

Read more... [Proposed ITAR Brokering Rules Published This Week]
 

Major changes to Harmonized System (HS) taking place in 2012

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Sunday, 18 December 2011 12:01

Is your company ready for the upcoming changes in HS 2012?

The end of 2011 is upon us and we wanted remind our clients of the major changes that are being made in 2012 to the Harmonized Tariff Schedule of the United States (HTSUS). These changes take place every five years or so. According to the latest information from the U.S. Government, the World Customs Organization's (WCO) recommended changes to the Harmonized System (HS) are scheduled to take effect on or about January 2012. The majority of these changes are in the food-related chapters (1-21); however, important changes will be made to the following chapters as well:

Read more... [Major changes to Harmonized System (HS) taking place in 2012]
 

Proposed Export Rules for Gas Turbines & Vehicles, Public Comment Until Jan 2012

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Friday, 09 December 2011 11:39

This week the U.S. Government published two proposed rules that address gas turbine engines, vehicles, and related items that the President determines no longer warrant control on the United States Munitions List (USML).

The comment period for both sets of rules closes on January 20, 2012. The State Department proposed rules are available here (gas turbines) and here (vehicles); and the Commerce Department proposed rules are available here (gas turbines) and here (vehicles).

 

US Eases Economic Sanctions on South Sudan

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Thursday, 08 December 2011 10:20

In today's Federal Register, the Department of the Treasury's Office of Foreign Assets Control ("OFAC") published an amendment to the Sudanese Sanctions Regulations (31 CFR part 538).

OFAC issued two general licenses that authorize all activities and transactions relating to the petroleum and petrochemical industries in the Republic of South Sudan and related financial transactions and the transshipment of goods, technology, and services through Sudan to or from the Republic of South Sudan and related financial transactions.

Read more... [US Eases Economic Sanctions on South Sudan]
 

Satellite Export Controls Bill Introduced in Congress

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Friday, 04 November 2011 00:00

If your one of the folks in this town who follow the Obama Administration's ongoing efforts to reform U.S. export control laws, you know that control of satellite and related technologies is a hot button issue on Capitol Hill. Indeed, officials both on and off the Hill will frankly admit that it is best to leave satellite controls on the back burner until other, less controversial matters are addressed.

This week the Ranking Member of the House Foreign Affairs Committee, Rep. Howard Berman (D-Calif.) and Rep. Don Manzullo (R-Ill.), Chairman of the Foreign Affairs Subcommittee on Asia and the Pacific, introduced the "Safeguarding United States Satellite Leadership and Security Act of 2011". On the surface, this seemingly straightforward and short bill (its just about 350 words), reads like something most policy watchers on the Hill and the Obama Administration could rally around. But as with most things related to export controls, you need to dig a little deeper and plumb the depths of official Washington to get the whole story.

Read more... [Satellite Export Controls Bill Introduced in Congress]
 

Two U.S. Trade Security Policy Meetings Next Month

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Friday, 28 October 2011 09:40

The following trade security policy meetings were announced this week in the Federal Register:

The Defense Trade Advisory Group (DTAG) will meet in open session November 9 at the Department of State. DTAG members consists of private sector defense trade representatives, appointed by the Assistant Secretary of State for Political-Military Affairs, who advise the Department on policies, regulations, and technical issues affecting defense trade. The purpose of the meeting will be to discuss current defense trade issues and topics for further study.

Read more... [Two U.S. Trade Security Policy Meetings Next Month]
 

Export Control Violations Land Georgia Man Prison Time

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Thursday, 27 October 2011 00:00

The U.S. Justice Department announced this week that a Georgia man has been sentenced to nearly four years in prison for his role in plotting to supply Iran with U.S. military aircraft components. Michael Edward Todd, the former President of a Georgia company called The Parts Guys, was sentenced to forty-six (46) months in prison and ordered to pay a $10,000 fine and forfeit $160,362 for his role. 

This past summer, a dozen defendants in four countries were charged with allegedly conspiring to violate the Arms Export Control Act (AECA) and the International Emergency Economic Powers Act (IEEPA) by selling military components to Iran.The defendants had set up an elaborate network to evade U.S. sanctions that included businesses located in the United Arab Emirates and France. The components were for use in attack helicopters and fighter jets such as the Bell AH-1 attack helicopter, the UH-1 Huey attack helicopter, and the F-5 and F-4 fighter jets.

Read more... [Export Control Violations Land Georgia Man Prison Time]
 

Iran & Sudan Sanctions Regulations Amended

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Tuesday, 18 October 2011 00:00

by Jason Poblete

The Department of the Treasury, Office of Foreign Assets Control (OFAC), has amended the Iran and Sudan sanctions regulations to allow food to be exported and re-exported to these countries under a general license.

According to the final rule published by OFAC on October 12, 2011, "food" is defined as "items that are intended to be consumed by and provide nutrition to humans or animals in Sudan or Iran — including vitamins and minerals, food additives and supplements, and bottled drinking water — and seeds that germinate into items that are intended to be consumed by and provide nutrition to humans or animals in Sudan or Iran. The definitions also specify that food does not include alcoholic beverages, cigarettes, gum, or fertilizer."

Read more... [Iran & Sudan Sanctions Regulations Amended]
 
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