U.S. Exporters Will Benefit from Department of Commerce Adoption of Recommendations by W&G Attorney

April 11, 2014

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 President’s Export Council Subcommittee on Export Control and to Commerce’s 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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Wiltshire & Grannis LLP is a nationally recognized communications, information technology, international investment/national security, and litigation law firm. The firm’s clients include Fortune 500 companies, entrepreneurs, investors, trade associations, and non-profit organizations. As former senior government officials, federal prosecutors, Congressional counsel, and experienced litigators, W&G lawyers advise their clients on how government decision makers think, how legal and political institutions work in the real world, and how those institutions can affect a transaction or business plan. For more information, please visit www.wiltshiregrannis.com.

For further information, please contact Lara Knowles:  (202) 379-4533.



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