U.S. regulations of electronics, micro-electronics, and related software and technology exports largely fall under Category 3 of the Commerce Control List. We help clients assess the licensing requirements for their products and technologies and assist them in filing the appropriate applications. For example, we assist clients that produce or export:
- Analog-to-Digital Converters
- Capacitors
- Connectors
- Electron Tubes
- Electronic Components
- Flash Memories
- General Purpose Integrated Circuits
- Inductors (Coils)
- Printed Circuit Boards (4 to 24 layers)
- Processors
- Resistors
- Semiconductors and Semiconductor Manufacturing Equipment – which could include the likes of this product here and electric feedthrough connectors for the semiconductor industry.
Encryption
Electronic items containing encryption deserve special attention as the Bureau of Industry and Security separately regulates encryption technologies in Category 5, Part 2. Our attorneys have extensive experience with obtaining licenses and locating license exceptions for items with encryption features.
Recent Matters:
- Counseled software, scientific instrument, semiconductor, and programmable logic device companies with implementation of export compliance programs under the State Department’s International Traffic in Arms Regulations
- Led internal investigations of telecommunication and scientific instrument companies regarding potential violations of trade sanctions administered by the Treasury Department’s Office of Foreign Assets Control and the Commerce Department’s Bureau of Industry and Security
- Performed compliance audits and assisted with implementation of export compliance programs under the Commerce Department’s Export Administration Regulations for various information technology, networking, software, telecommunications, semiconductor, and semiconductor processing equipment companies
For more information, please contact Roz Thomsen.
