Approval from Washington

A shipment from one German company to another German company. It still needed approval from Washington.

Sounds odd. It is not.

A client builds a US chip into its own product. Under ITAR, that chip counts as a defence article. The US supplier holds the export licence, and that licence names who may receive the chip. The test lab they wanted to use is not on it.

Security screening done. Training on Controlled Unclassified Information (CUI) done. Neither of them replaces an ITAR authorisation.

ITAR follows the chip, no matter how deep it sits in your product. A new recipient means a retransfer request to the US Department of State before anything moves.
Fortunately, the client asked before shipping, so there is nothing to repair. The unit will go to the lab once the approval is in place.

Cases like this rarely end up on LinkedIn because nothing goes wrong. In my view, good compliance works exactly like that, quietly and without any drama.

Prefer your export compliance uneventful? Let’s talk.