BIS Asks for Comments on Burden of Keeping Export Records for Five Years
The Bureau of Industry and Security is asking for comments by March 17 on the burden of its five-year recordkeeping requirement for export transactions and boycott actions. The records can include memoranda, correspondence, contracts, invitations to bid, books of account, financial records, restrictive trade practice or boycott documents and reports, said BIS. The state of limitations for criminal actions for Export Administration Regulations violations is five years. Without the requirement that exporters and U.S. parties to boycott actions keep these records for five years, “potential violators could discard records demonstrating violations of the Export Administration Regulations prior to the expiration of the five-year statute of limitations,” said BIS.
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BIS said comments on the five-year recordkeeping requirement should address: (a) Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (b) the accuracy of the agency’s estimate of the burden (including hours and cost) of the proposed collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology.
(Federal Register 01/16/14)