Good Practice

STA – The (not-so) little license exception that could

Issue 10.
February 2021

Author
Donald Pearce
+ About author

Donald Pearce, a retired Special Agent from the US Commerce Department’s Bureau of Industry and Security, is the founder of Sentinel LLC, a consultancy focused on the intersection of international trade, technology, geopolitics, and security, and is also a Senior Advisor in the Global Risk, Monitorship, and Investigations Practice at trade advisory firm, Torres Trade Advisory. don@torrestradeadvisory.com

STA is perfectly suited for transactions where all parties to the transaction are mutually confident in their compliance systems.

The Export Administration Regulations (“EAR”) are often lauded for their use of license exceptions to reduce the regulatory burden on industry and government alike. As Export Control Reform saw an increase in the Commerce Department’s jurisdiction for parts, components, and technology previously considered munitions, a unique approach was needed to satisfy securit...

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