Export Control Blog

Hiatus

Time to make official what is already obvious -- this blog is on hiatus. I do hope to return in the near future, but there is no date certain. Thanks to everyone who has written wondering if I was taken down and subsequently sequestered by federal air marshals while attempting to access the 737's lavatory when departing National on my way home from Update.

Hope to see you soon. Until then feel free to email me with new corporate export control sites, tips, tidbits.

A New Export Blog

The very small fraternity of export control blogs has grown by one. Meet ExportLawBlog, an effort of the law firm Powell Goldstein. To get a flavor of it, here's a sampling from a recent post titled "Foreign Cows Moo a Sigh of Relief":

Nebraska-based Springer Magrath Co. pleaded guilty to criminal export violations and agreed to pay a $50,000 fine for its shipment of cattle prods to South Africa in 2002 without a license. Cattle prods and other discharge type arms such as stun guns are controlled by ECCN 0A985 and require a license for all destinations except Canada.

Springer Magrath is an agricultural supply house for cattle ranchers, selling such products as calf feeders and calf adoption powder, so it is safe to assume that the people there had never heard of the Commodity Control List prior to their visit from federal authorities. Frankly, many people who have heard of the Commodity Control List might be equally surprised that cattle prods appear on the list. And with good reason. Although cattle prods are, admittedly, often used as devices of torture, they are widely available from sources outside the U.S.

The way things are going I wouldn't be surprised to see 0A985 slapped with Short Supply controls, too. I hear the president needs cattle prods for the "alternative procedures" he favors for his "terrorist interrogation program".

New Corporate ExCon Link

Thanks to a reader whose modesty precludes me from acknowledging him by name, there is a new addition to our gallery of companies publishing export classification info to the web -- BMC Software. Look to the right (and perhaps scroll down a bit) for ECB's complete list of 56 such firms.

Why I'm Not Blogging This Week

Meet Jacob Declan Gearity, born August 29, 2006 in Cleveland, Ohio.

Guilty Update: I may not be blogging, but The Guardian did get a quote out of me on the latest air disaster in Iran.

Links Gone Corporate

Added some more links to corporate export control websites just now:

• McAfee
• GlobalSCAPE
• Cybersoft
• Symantec

Thanks to Matthew Lancaster (once again) of SAIC and Shelley Vybiral of Lord Corporation for the tips.

That brings the list up to 52 companies -- the large majority of them in the software business. Come on now, folks, I know there have got to be more of you sitting on this info -- do your customers a favor and get it up on the web. Then send me the link.

A Whale of a Link

Next time someone asks you what an ECCN is...send them here.

ECCN-O-Rama

Two newly discovered corporate export compliance sites for your reading pleasure -- open source solution provider Covalent and SMB software maker EMC Insignia. Both companies not only post their classifications, but also provide email contacts in case their export pages don't answer all your questions. Sweet.

Links to export control info for these two companies and 46 others (!) can be found in the lower right corner of this blog.

Tip of the hat to Matthew Lancaster of SAIC for the links. Know of others? Give me a shout.

Money Money Money

An apparently restless member of the federal workforce writes:

Hello,
Just wondering if you knew how much the average salary for a mid-level export control compliance rep for a large defense corporation would be.  I have 5 years government experience in compliance/export controls and was just curious about private sector employment.
Thanks for your help!

I guessed $60-80K depending on the company, location, and position, but I imagine that some of you have a better sense of this than I do. If you're feeling helpful, hit the comments link below and add your two cents.

Looking for an ECCN?

I've updated this blog's handy list of corporate export control sites (look to your right and scroll down a bit). Out with a few dead links and in with Agilent - Scientific Software, American Megatrends, Corrent, ESRI (pdf), EqualLogic, Information Security Corp, MKS, PGP (yes, that PGP), Qualcomm, and SmartFTP.

These and the earlier-listed companies are those I'm aware of which are savvy and customer-friendly enough to post their products' ECCNs to the web for the benefit of the exporting community. I remain befuddled as to why this isn't yet a more universal practice.

If your company similarly publishes classifications or other other export info and you don't see your name on the list, drop me a note with the link and I'll add it. Unless, of course, you enjoy answering all those "What's the ECCN for...?" calls and emails all day.

Top Ten Search Terms in December

I figure if you're reading this blog on what is remarkably both Christmas Day and the first day of Hanukkah I owe you at least a laugh or two. To that end, here are the most amusing search terms people used to reach Export Control Blog over the past month:

1. the agency that doesn't allow cigars into the us from cuba (Here you go, buddy.)
2. iran jsf (Clearly, someone is thinking very long term.)
3. nuclear export compliance under the ear (For all our sakes, I hope you're not relying solely on Google to meet this obligation.)
4. ECCN implication liability (Pretty sure you're not going to like the answer to this one.)
5. arms embargo DDTC china (Even CBP inspectors have given up trying to get DDTC on the phone -- this search originated from customs.gov.)
6. extraterritorial trade "international law" (From France, natch.)
7. "kill itar" (Easy there, cowboy...or maybe you're just looking for this?)
8. isro interview questions for telemetry tracking control and command network (Best of luck! You probably won't get the job if you mention the Entity List though, I hear it's a sore subject 'round ISRO.)
9. i am an export compliance specialist BIS (Good for you!)
10. If you are not licensed to export a certain item, but you exported the item, what happened? (Your question's way too deep for me, but perhaps your apparent philosophical soulmates at the US Embassy Jakarta can help.)