Export Controls:

  • Export Administration Regulations (EAR), administered by the Department of Commerce Bureau of Industry and Security (BIS) &

  • International Traffic in Arms Regulations (ITAR), administered by the Department of State Directorate of Defense Trade Controls (DDTC).

Do you know that the penalties for violating US export controls (covering hardware, software & technology) are staggering and can shut down your business? 

What are the risks? A penalty of up to $1M per violation and potential criminal prosecution.

Let DSG Global be your guide.


A good compliance program helps you understand your export licensing and compliance obligations.


Build strong controls so you don't inadvertently ship to restricted customers or sanctioned countries.


Robust internal controls serve as a mitigating factor against high export penalties.

Our Solution

  • Guidance on navigating all aspects of the EAR and ITAR

  • Jurisdiction determinations and DDTC USML & BIS ECCN product/technology classifications

  • Export authorization determination - What is the correct authorization for the requirement at hand, is there an available license exemption/exception, license applications, and post authorization management

  • Developing Export compliance programs – policies, procedures, and manuals

  • ITAR Registration guidance - Who needs to register and how to do so

  • Voluntary disclosures of violations under both the ITAR and EAR

  • DECCS (ITAR) and SNAP-R (EAR) Application assistance and oversight

  • Merger and Acquisition (M&A) due diligence – When acquiring a company, you are acquiring company export authorizations and violations.

  • Logistics and AES/ACE filings/reports – How to monitor if your freight forwarder is filing AES correctly, how to self-file AES, review routings and pricing to ensure which shipment options are best and which should be avoided.

 Case Study

Background

A U.S. subsidiary of a South-Korean company, routinely hired foreign nationals. However, they were not aware that transfer of controlled technology could require an export license for such “deemed exports”. They contacted DSG Global to analyze and provide guidance on this issue.

Challenge

DSG Global assessed the technology, confirmed which employees were considered “U.S. persons”, i.e., U.S. citizens, permanent resident aliens (“green card” holders), and individuals formally granted asylum status. We then confirmed which non-U.S. employees required authorization, and which non-U.S. employees did not.

Our Solution

Based on the jurisdiction and classification of the technology involved, only one of the foreign national employees required an EAR deemed export license. We interviewed the employee in question, assembled a complete biodata, and the export license was prepared and submitted.

Result

The company received an approved deemed export license within 45 days.

 Client Testimonial

“Deep is a true compliance professional and extremely well rounded. He offers both expertise and business acumen. He is creative in his approach to offer solutions that work within the regulations yet solve the business problem. It was a pleasure to work with him and I recommend his work to fellow compliance colleagues. ”
— Alison Harris, Director, Global Trade Compliance AVNET

Learn more about how Export Controls (EAR & ITAR) can help your organization with a complimentary consultation.