ICTS, FCC & Supply Chain

While OICTS imposes direct supply chain restrictions, it is not the only trade regulator imposing such restrictions: The Federal Communication Commission (“FCC”) also implements supply chain restrictions on electronics through its Covered List. Items regulated by the FCC include: surveillance equipment, communications equipment, drones (UAVs), power inverters, robotic devices, and routers. 

There are also less direct supply chain restrictions embedded within other trade controls. Your organization should evaluate sourcing restrictions based on U.S. sanctions (which may limit dealings with certain parties or countries), export controls (which could prevent your organization from sending technology to or getting returns from certain vendors and manufacturers-to-spec), and forced labor legislation, like the U.S. Uyghur Forced Labor Prevention Act (“UFLPA”). In addition, your organization should consider the possible implications of sourcing U.S. origin components for foreign production if that will create U.S. export control jurisdiction over foreign-produced items, especially when sourcing ITAR-controlled components, and restrictions on developing U.S. origin software or technology with collaboration from foreign partners.

If your organization is a federal contractor or subcontractor or has customers the are, you should be aware that sourcing from certain parties or countries may render your organization ineligible to sell goods or services to U.S. federal or state governments—or to sell goods or services to parties that are federal or state contractors.