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ARTICLE · 16 APRIL 2014

Ridiculous And Complicated: Proposed Changes To Support Documents For EAR Licenses

Reed Smith
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On April 9th, the Bureau of Industry and Security ("BIS") proposed a rule that would remove certain documentation requirements in connection with Export Administration Regulations ("EAR") license applications.

United StatesInternational Law
Leigh Hansson
Leigh Hansson
Carlos Aksel Valdivia
Carlos Aksel Valdivia
Joelle Laszlo
Joelle Laszlo
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On April 9th, the Bureau of Industry and Security ("BIS") proposed a rule that would remove certain documentation requirements in connection with Export Administration Regulations ("EAR") license applications. Export nerds are well aware that changing these requirements would go a long way toward streamlining the license application process (which is ridiculous and complicated). As the BIS itself notes, the IC/DV system is the vestigial appendage of a long-defunct Cold War relic. (That is not a quote; it's just the pent-up frustration of every export lawyer in the country.) For all its support documentation requirements, the IC/DV system nevertheless fails to obtain an affirmative statement from the ultimate end-user regarding the actual end use of the imported item.

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