Category Archives: ITAR

Trump administration eases regulations on exportation of small arms and ammunition.

January 19, 2020 By in CCL, Export, Import Export Attorney, ITAR, Uncategorized, USML Tags: , , , , , , , Leave a comment
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The Trump administration issued new rules related to the export licensing of firearms and ammunition products. Firearms and ammunition exports will now be managed by the Commerce Department and not the State Department.

In other words, small arms and ammunition shifts from the Department of State’s International Traffic in Arm’s Regulations US Munitions List to the US Department of Commerce’s Export Administration regulations.

ITAR concerns defense-related exports whereas EAR is “dual use” for commercial or military use, and therefore less strict export rules versus the State Department.

The new Trump administration rules also eliminates the $2,250 registration fee for gunsmiths and small companies who do not manufacture, or export firearms or ammunition.

The final rule will be published on January 23 rd and implemented 45 days later after formal publication.

If you have any questions how these new rules will impact your small arms or ammunition export business, contact experienced export compliance attorney David Hsu by phone/text at attorney.dave@yahoo.com or dh@gjatradelaw.com.

GitHub blocks developers in countries facing US trade sanctions.

July 28, 2019 By in compliance, ITAR, Uncategorized Tags: , , , Leave a comment
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GitHub (owned by Microsoft) is the world’s largest software development platform that provides hosting for software development version control using Git. It was acquired by Microsoft in 2018 for $7.5 billion and has recently started blocking developers in countries facing US trade sanctions.

For example, last week Github restricted the account of Anatoliy Kashkin, a 21-year-old Russian citizen who lives in Crimea. He was told his GitHub account had been restricted “due to US trade controls”.

The correspondence from GitHub advised Kashkin of GitHub’s US trade control policy – listing Crimea, Cuba, Iran, North Korea, and Syria as countries facing US sanctions. In addition to his website now showing a 404 error, Kashkin also can’t access his previous work.

GitHub’s website does advise that “Users are responsible for ensuring that the content they develop and share on GitHub.com complies with the U.S. export control laws, including the EAR (Export Administration Regulations) and the US International Traffic in Arms Regulations (ITAR)” and that “The cloud-hosted service offering available at Github.com has not been designed to host data subject to the ITAR and does not currently offer the ability to restrict repository access by country. If you are looking to collaborate on ITAR- or other export-controlled data, we recommend you consider GitHub Enterprise Server, GitHub’s on-premises offering.”

Besides banning accounts for individuals in Crimea, GitHub has also restricted developers in Iran.

If you want to ensure your company is in compliance with the Export Administration Regulations and the US International Traffic in Arms Regulations (ITAR), contact experienced compliance attorney David Hsu at 832-896-6288 or by email at dh@gjatradelaw.com, attorney.dave@yahoo.com.