As part of the Trump Administration’s increase in export and sanctions enforcement, the Commerce Department’s Bureau of Industry and Security plans to add 19 new enforcement personnel in their 11 regional offices during the government’s new fiscal year, which starts October 2018. This will lead to more announced and unannounced site visits to manufacturing and service facilities that make, distribute, and export dual use controlled goods. If your company needs to classify products, software or know how (what BIS calls ‘technology’) to ensure compliance with the Export Administration Regulations (EAR), now would be a good time to start. Many companies are surprised that their products are caught up in the Commerce Control List requirements for export licenses. It is also wise to have a written export compliance policy and procedures in place.
