In several recent posts we discussed EEI filing, how to determine ECCN, and what is meant by EAR99. It is important to understand that Export Administration Regulations apply to reexports as well as exports. Here is the definition of reexports from the BIS (Bureau of Industry and Security) and a link to their publication Reexport Controls.
A reexport is the shipment or transmission of an item subject to the EAR from one foreign country (i.e., a country other than the United States)to another foreign country. A reexport also occurs when there is “release” of technology or software(source code) subject to the EAR in one foreign country to a national of another foreign country.
Export best practices mean confirming that you are in compliance on all transactions. Don’t assume, validate!
Contact mitch@52.91.45.227 for assistance.