EXPORT ENFORCEMENT UPDATE: THE IMPORTANCE OF COMMODITY CLASSIFICATION

On 19 August, an article from Bass Berry & Sims highlighted 3 particular elements from a recent export control case which involved a $6.6 million penalty for Keysight Technologies, a US technology and software company, for 24 alleged violations of the International Traffic in Arms Regulations (ITAR).  The unauthorised exports were based on incorrect commodity classification, and such ITAR exports are tightly controlled to China, Russia, as well as by US allies.  It emphasises that software and technology cross national borders easily – but export authorisation may still be required.  The firms stresses that the key takeaway is to dedicate resources to compliance – especially classification and jurisdiction. 

https://www.bassberrygovcontrade.com/commodity-classification-export

 

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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