News from Reeves & Dola, LLP 
*** R|D ALERT ***

October 5, 2020



On October 5, 2020, the Commerce Department's Bureau of Industry and Security (BIS) published a Final Rule in the Federal Register to amend the Export Administration Regulations (EAR) by revising, in part, the licensing policy for items controlled for crime control (CC) reasons. BIS announced that it is making the changes to "clarify to the exporting community that licensing decisions are based in part upon U.S. Government assessments of whether items may be used to engage in, or enable violations or abuses of, human rights including those involving censorship, surveillance, detention, or excessive use of force."
The Final Rule revises paragraph (b) of 15 C.F.R. ยง 742.7 to expand its licensing policy as it applies to CC-controlled items, as well as expand its consideration of human rights beyond CC-controlled items. A new subparagraph (b)(1) has been created to instruct that BIS "generally will consider favorably, on a case-by-case basis, license applications for a CC-controlled item unless there is civil disorder in the country or region of destination or if BIS assesses that there is a risk that the items will be used in a violation or abuse of human rights." Additionally, a new subparagraph (b)(2) has been added to make clear that BIS will consider the licensing policy set forth in new subparagraph (b)(1) when reviewing items controlled for reasons other than CC, with the exception of items controlled for short supply.


The nonprofit industry group, the F.A.I.R. Trade Group, is offering a two-hour webinar on the Firearms and Ammunition Excise Tax (FAET) on Thursday, October 15, 2020. The webinar, which will be held from 1:00 pm to 3:00 pm Eastern, will be taught by Robert Fielding, an Excise Tax Auditor who has been with the Alcohol and Tobacco Tax and Trade Bureau (TTB) for 12 years. His group conducts FAET audits of industry members out of the Eastern 1 Field Office.

The webinar will review in detail the FAET return and will offer insight on common compliance issues and what to expect during a TTB audit. The cost of the webinar is $75/person. To register, please click here.

The F.A.I.R. Trade Group ( is a 501(c) (6) organization dedicated since 1994 to protecting the interests of the firearms and ammunition import and export community. 

The above alert is for informational purposes only and is not intended to be construed or used as legal advice. Receipt of this alert does not establish an attorney-client relationship.

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About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.

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