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Export licensing and Compliance.


When it comes to export licensing or compliance with the ITAR or the EAR, why take chances?

 
For over 20 years, FD Associates has provided expert guidance to companies exporting commodities and services controlled for export under the ITAR and EAR. Our team of export compliance specialists offers hands-on practical experience in the day-to-day aspects of shipping and exporting under the ITAR. We can be a one-stop resource for companies in: 
 
  • Assessing The Specific Export Compliance and Licensing  Needs Of Your Company.
  • Recommending, Developing And Implementing An Export Compliance System.
  • Providing Licensing Support Including Preparation, Submission and Liaison with Government Reviewers.
  • Providing ITAR and EAR Export Compliance Training, Either at Your Company’s Facilities or at our Semi-Annual Export Seminars . 
  • Conducting ITAR and EAR Audits and Procedures Reviews
  • Provide Assistance in Preparing Voluntary Disclosures Related to ITAR and EAR Non-Compliance
When it comes to export compliance consulting and export licensing services, why take chances with novices, newbies or “virtual” companies? FD Associates is the premier export consulting company providing clients professional, accessible resources with experience in all aspects of exporting and compliance with the ITAR and the EAR. See "Our Associates" for more information on our personnel or call us for a free consultation at 703-847-5801 or email info@fdassociates.net.
 
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Consultant's Corner


 

Designating The Correct USML Category XI Sub-subparagraphs On DSP License Submissions

By John Herzo,

Senior Associate.

 

On December 29, 2014 the Department of State posted an announcement to its webpage regarding the designation of USML category sub-subparagraphs on future DSP license submissions for the newly revised USML Category XI Military Electronics that went into effect on December 30, 2014 due to Export Control Reform.  The changes to this USML Category were significant and in order to make this Category a positive list of enumerated items, numerous sub-subparagraphs were added to the Category (a sub-subparagraph is a section that includes a Roman numeral, e.g., Category XI(a)(3)(v)). 

The December 29th guidance relates to situations where a defense article meets the criteria for multiple sub-subparagraphs of USML Category XI and how to correctly reference them on a DSP submission. 


If your defense article meets the criteria of multiple sub-subparagraphs you should:

  •      Choose the predominant sub-subparagraph as the primary entry for the USML Category Block (DSP-5 Block # 11; DSP-61 Block # 13; and DSP-73 Block # 14);

  • Bona fide regular employees holding a security clearance issued by the host government do not require screening

The Department of State in its announcement warned of potential “Return Without Action” if the incorrect sub-subparagraph is used in the USML Category Block of the application.  Of more concern, the Department of State warned of potential significant delay as designation of an incorrect sub-subparagraph may not be detected until after the technical review of the DSP submission by the staffing points (DOD, RSAT, DRL etc) has been completed.

If you have any questions regarding these requirements please contact us.