Commerce Department Export Enforcement

By Stewart Baker ([email protected]) & Ed Krauland ([email protected])

Several clients recently have received informal visits from two-person teams from the U.S. Commerce Department's Bureau of Export Administration ("BXA"), Office of Export Enforcement. These visits apparently have been following up on applications from nationals of certain disfavored countries, such as China and Iran, for visas that would allow them to work for major U.S. exporting companies on a temporary basis. The discussions with the BXA enforcement personnel generally have focused on the kinds of technology that would be disclosed to the foreign nationals during their visits to our clients' premises, to ensure that the companies are aware of U.S. export control restrictions and have the necessary export licenses in place for foreign national visits or employment.