Friday, April 23, 2010

It's Time For A Change - Export Reforms

Just when the Wizard figured out when to consult the BIS and the DDTC along with the differences between the CCL and the USML, all the rules are going to change. While some might not be happy about all of the changes, others will probably find the consolidation much easier to understand.

This week, Defense Secretary Gates unveiled plans to simplify the export process by consolidating the export functions. This proposed unification would take place in three stages to allow for regulatory changes along with the required legislative approvals and other challenges.

The proposed reform includes changes to:

1. Export Control Lists
The Commerce Control List (CCL) would be combined with the U.S. Munitions List (USML)

A single licensing agency would be created to have jurisdiction over defense and dual-use items and technologies.

3. Enforcement
A single agency would be created to enforce export controls currently shared by the Commerce Department, Department of Homeland Security and the FBI.

4. Information Technology
A new I.T. system would be implemented for licensing and enforcement.

While there are numerous hurdles involved in accomplishing these goals, the outcome should produce a more efficient trade friendly agency. The trade community should continue to watch for updates. The proposed reforms will affect the way companies do business. The new export process will require changes to procedures, internal processes, training and many other activities.

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