MEU Rule Still Causing Challenges, Compliance Officials Say
Out of all the government’s export control regulations, two aerospace industry officials said they are spending the most time trying to comply with the Bureau of Industry and Security’s military end-user and end-use rule.
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Laura Molinari, a compliance official with Boeing, said the MEU rule has been “very difficult.” Molinari, speaking during a Jan. 27 conference hosted by the Massachusetts Export Center, said some exporters are still struggling to understand how best to comply with the rule and are taking a very conservative licensing approach to ensure they don’t violate the restrictions, which were introduced in 2020 and imposed more due-diligence requirements for exports to certain countries (see 2004270027).
She said the rule is particularly tricky because it includes a “definitional component” that applies to specific shipments and a “list component,” which subjects five countries to the restrictions: China, Russia, Venezuela, Myanmar and Cambodia. “I think people are having issues comprehending that the two of [those components] come into play,” Molinari said.
Dirk Petersen, a trade compliance with AMETEK Aerospace, echoed Molinari’s points. “Definitely the MEU is where I spend most of my time right now,” he said. Industry has faced challenges implementing the rule since it was introduced (see 2007090075) and even after BIS issued guidance (see 2007090075). A BIS spokesperson pointed to the agency's December update of its MEU frequently asked questions.