Contributing Lawyers

Canada

Cyndee Todgham Cherniak

United States

Susan Kohn Ross

Australia

Andrew Hudson



BIS Issues New Guidance Documents

In January 2010, BIS posted on its website updated guidance for freight forwarders, see http://www.bis.doc.gov/complianceandenforcement/freightforwarderguidance.htm. More recently, BIS posted an updated version of its Export Management System. Now called the Export Management and Compliance Program, the new EMCP can be found at http://www.bis.doc.gov/complianceandenforcement/emcp_guidelines.pdf. Also of interest is the self-assessment tool which can be found at http://www.bis.doc.gov/complianceandenforcement/revised_emcp_audit.pdf. Together these tools allow exporters to benchmark how they are doing with their overall export compliance. Of course, these BIS materials only apply if your exports are subject to Commerce/BIS jurisdiction. If your goods are intended for the military or law enforcement or are of a similar nature and so subject to State/ITAR control, BIS’ EMCP and self-audit materials are still valuable tools to use as a starting point to test your overall level of export compliance.

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