A significant new obligation has been applied by the U.S. government on many exporters, but it’s entirely likely those companies are unaware that this obligation is being provided on the face of granted licenses. In working with the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), we’ve learned of a new mandatory license condition requirement being attached to all deemed export licenses issued going forward beginning in July 2018. Additionally, this new license condition will also be attached to any deemed export licenses for which renewals are granted after July 2018. No notice was provided by BIS before implementing the change, and the agency has given no indication it will be publishing guidance for exporters. I’ll do so in this article, as it’s essential that exporters engaging with BIS understand this procedural change.
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