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November 18, 2008 

BIS Posts Q&As on Proposed License Exception ICT

The Bureau of Industry and Security has published on its website a number of questions and answers on the proposed rule establishing License Exception Intra-Company Transfer (ICT).

License Exception ICT would allow an approved “parent company” and its approved wholly-owned or “controlled-in-fact” entities to export, reexport, or transfer (in-country) many items on the Commerce Control List (CCL) among themselves for internal company use only. Prior authorization from BIS would be required to use ICT.

Public comments on the proposed rule were due yesterday, November 17, 2008.

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