U.S. Exporters Will Benefit from Department of Commerce Adoption of Recommendations by W&G Attorney
The paperwork burden on American exporters will be significantly lessened under a proposed amendment to export control regulations just published in the Federal Register. This regulatory change broadly adopts suggestions made by Cecil Hunt in a memorandum he provided to the Presidents Export Council Subcommittee on Export Control and to Commerces Bureau of Industry and Security.
The key change will be the elimination of the requirement that International Import Certificates (ICs) and Delivery Verifications (DVs) be obtained from foreign authorities for many licensed exportations from the United States. Mr. Hunt had called these requirements a burdensome relic of post-World War II multilateral control arrangements. Export control and enforcement needs are better met, in his view, by continued and broadened use of statements obtained by the exporter from the consignee/end-user, without the involvement of foreign authorities. The BIS proposed rule adopts this approach.
Mr. Hunt focuses his practice on national security and foreign policy related governmental requirements affecting global business operations, such as export controls, economic sanctions, national security review of foreign acquisition of U.S. firms, and the U.S. anti-boycott regulations
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