Kotz Sangster regularly represents clients in connection with compliance with the wide variety of laws and regulations that impact defense contractors, exporters and importers, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), anti-boycott regulations, Office of Foreign Asset Control regulations, and the Foreign Corrupt Practices Act.
We work closely with our clients to develop export control compliance programs for companies of any size so they can ensure they do not inadvertently violate export control laws. These export compliance plans and Technology Control Plans (TCP) are developed with the specific aim that they will be implemented into the day-to-day business operations of our clients.
Furthermore, Kotz Sangster will aid our clients in determining which set of U.S. Government regulations apply to the export of products and technical information from the United States: EAR for civil and dual use items or ITAR for exports of military and defense related items. This determination can be difficult, as many key items and technologies (e.g., aircraft parts, electronic components, etc.) fall within the grey area separating the two sets of regulations. Kotz Sangster will draft and obtain formal determinations (Commodity Jurisdictions) from the U.S. Department of State on behalf of our clients.
Kotz Sangster also obtains licenses and other export authorizations from the U.S. Government on behalf of our clients. These include Department of Commerce and Department of State export licenses (both for export and for the employment of foreign persons in the United States), Technical Assistance Agreements, Manufacturing License Agreements, Warehouse and Distribution Agreements, temporary export, and re-export authorizations.