As many seasoned trade compliance professionals have pointed out you need to be careful what you ask for. A good example of that is the proposed revision to Part 129 of the ITAR. If you have not read it carefully you most certainly should.
Additionally, if you want a right between the eyes assessment of its significant impact and implications, read the two articles in Jim Bartlett’s Ex/Im Daily Update from Clif Burns, Counsel, at Bryan Cave LLP’s Washington DC Office. The first titled “DDTC Releases New Proposed Brokering Rules” is in the Monday, December 19th, 2011, edition. The second: “And It Just Gets Worse and Worse“ is in yesterdays, December 21st edition.
If your organization or you are in any way affected by these changes, I strongly encourage you to take the time and make the effort to submit comments. They are due by February 17th, 2012. Do not expect the US Government to appreciate or understand the impact and implications, unless you tell them. In the context of changes like this or evolving Export Control Reform, you have got to speak up. If you do not, you deserve what you get. Remember: New does not necessarily mean better.
NOTE: If you are an Empowered Official or trade compliance professional at any level and you are not already on distribution for Jim Bartlett's Ex/Im Daily Update, you most definitely need to be! Make your request directly to Jim at James.Bartlett@NGC.com. I guarantee you will find it invaluable. Consider it a fitting Christmas present to yourself and your organization.
Subscribe to:
Posts (Atom)