THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 83, October 2019

Commerce Department warns suppliers on exports to Pakistan 

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By Jonathan McLaughlin and Valerie Lincy, Wisconsin Project on Nuclear Arms Control www.wisconsinproject.org   On 30 August 2019, the Bureau of Industry and Security (‘BIS’) of the US Commerce Department published due diligence guidance for exports to Pakistan.1 The guidance reviews supplemental licence requirements for the country under the Export Administration Regulations (‘EAR’), including requirements for parties that appear on Commerce’s Entity List, and recommends a number of best practices for trade with Pakistani end-users. The new guidelines are intended to mitigate recent illicit procurement patterns in Pakistan. Commerce’s guidance includes a review of the end-use and end-user export restrictions...

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