Every trade compliance department has gaps. Usually unintentional, these gaps can cause inadvertent violations of U.S. Government federal regulations such as the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Foreign Trade Regulations (FTR), or Office of Foreign Assets Control (OFAC) Regulations, among others. A healthy trade compliance department is aware of the potential for gaps in compliance and conducts regular audits and assessments to… Read More

When I worked for Raytheon Missile Systems in Tucson, Arizona, my morning drive almost always consisted of, at some point, passing protesters outside of the campus. So I was not surprised when I read a Defense News article about protestors blocking the entrance to a Raytheon facility in Rhode Island to protest Raytheon sales to Saudi Arabia,… Read More

When the Foreign Assistance Act (FAA) of 1961 was passed, it included Section 502B(a)(1) asserting that a principal goal of U.S. foreign policy “shall be to promote the increased observance of internationally recognized human rights by all countries.”[1] Further, Section 502B(a)(2) confirms that absent the exercise of a presidential certification of, “extraordinary circumstances,” no security… Read More

Historically the U.S. Government has implemented policies to protect the safety of jobs within the U.S. Defense Industry. For example, as taken from An Overview of Small Business Contracting, “During World War II and then again after the outbreak of fighting in Korea, Congress found that the existence of thousands of small business concerns was… Read More

The Biden Administration started its term with a declaration that surprised many in the defense industry: a halt to offensive arms sales to Saudi Arabia and several other Gulf Nation countries including the United Arab Emirates (UAE) 1. This policy shift was announced in February 2021 after a significant increase in defense exports to the… Read More

Takeaways for exporters of USG technology related to recent USG compliance investigations. Whether you are advising on International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), Office of Foreign Asset Controls (OFAC), or the many other significant regulations affecting international trade, we as trade compliance professionals are often placed in the challenging position of… Read More

The Defense Industry does not offer many opportunities for unbridled creativity, except in one place: offsets. For the uninitiated, offsets are contractual obligations where the purchaser attempts to “offset” the cost of the contract by mandating that a portion of the work be performed locally. There are two flavors of offsets: direct and indirect. Direct… Read More