BIS Publishes Comments on Proposed License Exception Intra-Company Transfer

The Bureau of Industry and Security has posted the public comments submitted on the proposed rule to establish License Exception Intra-Company Transfer (ICT) that was issued by BIS on October 3, 2008.

BIS received 18 comments on the proposed rule from individuals, companies and trade associations. In general, the comments commended BIS for making the effort to reduce the licensing burdens on U.S. companies and their affiliates. However, most of the comments noted that many aspects of the proposed rule in its current form were too burdensome burdensome. Several of the comments indicated that the proposed ICT license exception was in practice similar to the rarely used Special Comprehensive License that is available to U.S. exporters today.

The comments can be found at the following link (note that this is a very large PDF file (12MB)).