Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts"

Transcription

1 Olga Torres, Associate Ol T A i t Braumiller Schulz LLP International Trade Law

2 Overview Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts Common Pitfalls and Best Practices

3 Introduction to Braumiller Shl Schulz International Trade Law Firm And Braumiller Schulz hl Consulting LLP Trade Professionals Include: International Trade Attorneys Trade Advisors Licensed Customs Brokers International Freight Forwarders Former Customs Auditors

4 A Few of Our Services... Export and Import Compliance Programs and Compliance Manuals Export Licensing and Agreements Technology Control Plans Export and Import Compliance Audits Free Trade Agreements Duty Savings and Foreign Trade Zones Trade Compliance Training Fines, Penalties, and Forfeitures

5 Customs Brokerage and Freight Forwarding Services Filing export documents AES records Bills of Lading, Air Waybills Commercial Invoices Packing Lists Many others! Customs entries and supporting documentation Customs Form 7501 or 3461 a(1)(a) List: all documents associated with the import Supply Chain Logistics Services

6 Why Trade Compliance? Export Security Trade Secrets/ Economic Espionage Military Controls Fighter in the Field Trade Policy Economic Sanctions and Embargoes

7 Why Trade Compliance? (cont d) Import Security C TPAT and AEO voluntary accreditation regimes Duties/Fees Consumer Product Safety Trademark, Copyright Violations Many other agency regulations enforced (EPA, FWS...)

8 Why Trade Compliance (cont d) Companies Require It! Requests for ITAR Registration Numbers Requirements that business partner is AEO or C TPAT certified Terms and Conditions Specify It: EXPORT COMPLIANCE: Purchaser agrees that its business shall be conducted d in accordance with ih all laws of the United States and its foreign jurisdictions, and in a manner that will always reflect the highest standards of ethics. Diversion of the Product contrary to US U.S. law is prohibited. In particular, Purchaser agrees to comply with U.S. government export control laws and regulations...

9 U.S. Overview: Who Regulates What? Customs & Border Protection Policemen to enforce regulations 19CFR Dual Use Items Bureau of Industry & Security Export Administration Regulations (EAR) 15CFR Defense Items Directorate of Defense Trade Controls International Traffic in Arms Regulations (ITAR) 22CFR Other Agencies DEA, NRC, OFAC, Census Bureau

10 Authorities Who Control lus U.S. Imports Animal and Plant Health Inspection Service (U.S. Department of Agriculture) U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (U.S. Department of Justice) U.S. Fish and Wildlife (U.S. Department t of the Interior) U.S. Patent and Trademark Office (U.S. Department t of Commerce) Food and Drug Administration (U.S. Department of Health and Human Services) U.S. Customs and Border Protection enforces all imports at US U.S. borders. (U.S. Department of Homeland Security)

11 Authorities i Who Control lus U.S. Exports State Dept s Directorate of Defense Trade Controls (DDTC) controls defense articles, defense services, and related technical data, including most space related articles ITAR. Commerce Dept s Bureau of Industry and Security (BIS) controls dual use items EAR; and the Bureau of Census controls trade statistics and SEDs Treasury Dept s Office of Foreign Assets Control (OFAC) oversees embargo and sanction lists OFAC regulations. Homeland Security Dept s U.S. Customs and Border Protection enforces all exports at U.S. borders.

12 Supply Chain Participants Examples: Factory / Supplier Truck/Rail Transport International Air/Ocean Carrier Freight Forwarders 19 CFR Licensed Customs House Brokers (Brokers, or LCHBs) 19 CFR 111.1

13 Starting a Compliance Program Your company wants to start importing or exporting and has no compliance program. Where to start?

14 U.S. Export Resources Dept. of Commerce International Trade Administration (ITA) trade Market Access, Matching, Eliminating Trade Barriers U.S. Commercial Service USA TRADE Dept. of Commerce Bureau of Industry and Security Dept. of Treasury Census Bureau trade/regulations/index.html trade/regulations/index html Dept. of State Directorate of Defense Trade Controls

15 U.S. Import Resources Informed Compliance Publications available at: ce_pubs/icp021.ctt/icp021.pdf CROSS System for tariff classification rulings

16 Export Controls Generally Dual Use Items: Export Licensing and the Wassenaar Arrangement Items Classified under ECNs, or ECCNs Deemed Exports Defense Articles: Export Licensing for Military Items Df Defense Articles Defense Technology Transfers Defense Services

17 Denied Party Screening Lists to check BIS lists EAR Part 764 OFAC Sanctioned Countries List ex.shtml Federal Register Other lists...

18 Denied dparty Screening Non U.S. Examples Australia Australia Consolidated List Listing of Terrorist Organizations Implementation of UN Security Council Sanctions Canada Anti-terrorism Act Currently Listed Entities Canada Cumulative Warning List OSFI Consolidated List of Entities OSFI Consolidated List of Individuals Royal Canadian Most Wanted List Chile Most Wanted Fugitives European Union EU Financial Sanctions EU List of Persons, Groups and Entities Involved in Terrorist Acts List of Airlines Banned Within the EU UN Persons Publicly Indicted by the ICTY for war crimes Sanctions or Restrictive Measures in Force Hong Kong Wanted Persons India Most Wanted Terrorist, Insurgent and Extremist Groups Interpol Most Wanted Israel Palestinian Suspects Wanted for Terrorism and Other Crimes Palestinian Terrorist Wanted People Involved bombing the Jewish Community Center in Argentina (AMIA) The Leading Palestinian Terrorist Organizations

19 Trade Management Software Denied Party Screening Free Trade Agreements Export License Management Deemed Export Management Inventory Management Classification Examples: net/ com/vc/vc cfm

20 Outsourcing Services to a Broker or Freight Forwarder Services May Include Customs and Export Clearance, Paperwork Commodity Classification (HTS, Licensing) Supply Chain Logistics i

21 Outsourcing Services to a Broker or Freight Forwarder (cont d) Limiting the Number of Brokers, Forwarders Used Btt Better service More control (consider also WTO Incoterms) Best Practices Written Compliance Procedures Standard Operating Procedures (SOPs) with client RECORDKEEPING 5 years

22 BIS charged: Pitfalls: The DHL Case on 8 occasions between June 2004 and September 2004, DHL caused, aided and abetted acts prohibited by EAR when it transported items subject to the EAR from the US to Syria 90 exports between May 2004 and November 2004 DHL failed to retain air waybills and other export control documents required to be retained under Part 762 of the EAR. OFAC charged that t DHL violated various OFAC regulations lti between 2002 and 2006 relating to thousands of shipments to Iran and Sudan. Like DHL's EAR violations, its OFAC violations primarily involve DHL's failure to comply with applicable record keeping requirements.

23 The Outcome BIS and OFAC entered into the joint settlement agreement with DPWN Holdings (USA) and DHL Express (USA). The settlement amount: $9.44 million "Large scale compliance breakdowns lead to significant sanctions aimed at ensuring that freight forwarders put into place and maintain necessary measures to meet their compliance responsibilities. "

24 The DHL Case Four times greater than any civil penalty on BIS s Major Cases List and far exceeds freight forwarder settlements to date.

25 Key Points from the DHL Case U.S. export controls typically do not consider freight forwarders to be the exporter, but OFAC pursued DHL because it appeared to have exported or attempted to export multiple shipments. BIS, on the other hand, characterized DHL s involvement with those exports only as aiding or abetting someone else s export. BIS threatened DHL with $250,000 per violation. Even though it could have done the same, OFAC started settlement negotiations at $50,000 or significantly lower amounts per violation.

26 BIS Red Flags htm Customer or purchasing agent reluctant to offer information about end use Product's capabilities do not fit buyer's line of business Customer willing to paycash for a very yexpensive eitem when terms sof sale would normally call for financing Customer has little or no business background Customer is unfamiliar with product's performance characteristics but still wants it Freight forwarding firm is listed as the product's final destination Shipping route is abnormal for the product and destination

27 Export Penalty Examples Criminal Sanctions: A fine of up to $1,000,000 or up to ten years in prison, or both, per violation. Civil Sanctions: A fine of up to $500,000 per violation. Additionally, i for any violation i of the ITAR either ih or both of the following may be imposed: The denial of export privileges; iil and/or Seizure/Forfeiture of goods.

28 Best Practices Senior Management Commitment to Compliance Written Compliance Procedures Recordkeeping Procedures Ongoing Compliance Training i Monitoring: Audits, Reviews, Corrective Measures Updates on U.S. restrictions, sanctions, licensing, denied parties, country lists Review the lists Watch for Federal Register notices Refer to online resources

29 Best tpractices (Cont d) Denied Party Screening Employees Vendors Manufacturers Buyers Awareness of Red Flags Ongoing Communication with Broker, Freight Forwarder, Trade Attorney, and Other Experts In the event of an error, consider voluntary disclosure

30 Stay Current! Watch for Updates: Automated t export/import t filings HTS tariff codes and rates VEU program updates Denied party lists Country sanctions Licensing requirements

31 Contact Information Olga Torres, Associate Braumiller Schulz LLP International Trade Law

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls

COMPUTER & INTERNET. Westlaw Journal. Expert Analysis Software Development and U.S. Export Controls Westlaw Journal COMPUTER & INTERNET Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 31, ISSUE 1 / JUNE 13, 2013 Expert Analysis Software Development and U.S. Export Controls

More information

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

5/29/2015. Export Compliance Overview. Agenda. Regulatory Overview. In the News. Key Program Elements. Quiz

5/29/2015. Export Compliance Overview. Agenda. Regulatory Overview. In the News. Key Program Elements. Quiz Export Compliance Overview William Barthell Global Trade Compliance Symantec Corporation June 19, 2015 Agenda Regulatory Overview In the News Key Program Elements Quiz Copyright 2015 Symantec Corporation

More information

Key Elements of International Trade Compliance. Presented by:

Key Elements of International Trade Compliance. Presented by: Key Elements of International Trade Compliance Presented by: International Business Transactions International Civil Litigation 2 I. Introduction Every international shipment implicates at least TWO legal

More information

A Primer on U.S. Export Controls

A Primer on U.S. Export Controls A Primer on U.S. Export Controls Presentation for the Pacific Northwest Defense Coalition By Akana K.J. Ma Partner, Ater Wynne LLP 16 July 2013 (503) 226-8489/akm@aterwynne.com Akana K.J. Ma 2013 All Rights

More information

Global Developments in Export Control Laws. Steven Brotherton, Partner May 1, 2008

Global Developments in Export Control Laws. Steven Brotherton, Partner May 1, 2008 Global Developments in Export Control Laws Steven Brotherton, Partner May 1, 2008 Today s Goals 1. Overview of global export control developments 2. Discuss impact on global movement of goods, people and

More information

Harvard Export Control Compliance Policy Statement

Harvard Export Control Compliance Policy Statement Harvard Export Control Compliance Policy Statement Harvard University investigators engage in a broad range of innovative and important research both in the United States and overseas. These activities

More information

EXPORT CONTROLS COMPLIANCE

EXPORT CONTROLS COMPLIANCE Responsible University Official: Vice President for Research Responsible Office: Office for Export Controls Compliance Origination Date: May 1, 2014 EXPORT CONTROLS COMPLIANCE Policy Statement Northwestern

More information

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3

Mastering Global Trade Compliance for Growth Through Export. Track 1 Session 3 Mastering Global Trade Compliance for Growth Through Export Track 1 Session 3 Julie Gibbs Director BPE Global Jgibbs@bpeglobal.com 415-595-8543 www.bpeglobal.com 2 Abstract It's not a small world after

More information

Export Compliance Certificate Program

Export Compliance Certificate Program Business and Management Export Compliance Certificate Program Accelerate Your Career extension.uci.edu/export In today s competitive business market, leaders are appointed based on credentials and experience.

More information

What Every Contract Manufacturer Needs to Know About Export Compliance

What Every Contract Manufacturer Needs to Know About Export Compliance A Compliance Assurance LLC White Paper P.O. Box 211415 Royal Palm Beach, FL 33421 561.641.5036 www.wearecompliant.com What Every Contract Manufacturer Needs to Know About Export Compliance By James Anzalone,

More information

Filing your EEI into AES

Filing your EEI into AES Filing your EEI into AES Presenter Korrie Thomas Director, Compliance Houston Joined BDP in 2011 24 years of trade experience Licensed Customs broker since 1994 korrie.thomas@bdpinternational.com 281-775-8338

More information

EXPORT CONTROLS BASIC ELEMENTS FOR FACULTY

EXPORT CONTROLS BASIC ELEMENTS FOR FACULTY EXPORT CONTROLS BASIC ELEMENTS FOR FACULTY EXPORT COMPLIANCE Stony Brook University Export Controls Compliance Website: http://www.stonybrook.edu/research/osp/exportcontrols.shtml Stony Brook Policy P212:

More information

THE UNIVERSITY OF ALABAMA IN HUNTSVILLE EXPORT CONTROL INFORMATION

THE UNIVERSITY OF ALABAMA IN HUNTSVILLE EXPORT CONTROL INFORMATION THE UNIVERSITY OF ALABAMA IN HUNTSVILLE EXPORT CONTROL INFORMATION Number Division Office of Research Security (ORS) Date April 16, 2014 Purpose To provide guidance when faculty, staff and students are

More information

Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations

Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations Session Title: Mitigating the Financial and Compliance Risks Associated with International Shipments Supporting Global Collaborations Presented by: Norm Hebert, Director, International Research Administration,

More information

Fundamentals of Export Controls Compliance for University Research Administration

Fundamentals of Export Controls Compliance for University Research Administration Fundamentals of Export Controls Compliance for University Research Administration Jennifer Saak, Ph.D. June 26, 2014 About MAXIMUS Established in 1975; Headquartered in Reston, Virginia Largest publicly

More information

Freight Forwarder Roles in the Export Transaction. Theresa Sekula

Freight Forwarder Roles in the Export Transaction. Theresa Sekula Freight Forwarder Roles in the Export Transaction Theresa Sekula Presenter Theresa Sekula Manager, BDP Corporate Compliance Team Joined BDP in 2005, various roles including marine procurement, operations,

More information

University of Louisiana System

University of Louisiana System Policy Number: M-(16) University of Louisiana System Title: EXPORT CONTROL Effective Date: October 26, 2009 Cancellation: None Chapter: Miscellaneous Policy and Procedures Memorandum The University of

More information

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions

Second Annual Impact of Export Controls on Higher Education & Scientific Institutions The following presentation was presented at the Second Annual Impact of Export Controls on Higher Education & Scientific Institutions Hosted by Georgia Institute of Technology In cooperation with Association

More information

Export Compliance for Canadian Companies

Export Compliance for Canadian Companies supply chain & logistics Export Compliance for Canadian Companies CITT Webinar Series Date: Wednesday, October 19 2016 Time: 12pm EST Hosted by: Kevin Riddell, CCLP Presenter Info Kevin Riddell, CCLP Director,

More information

Export Controls: What are they? Why do we care?

Export Controls: What are they? Why do we care? Export Controls: What are they? Why do we care? Laura Langton, PhD Export Control Manager langton@wustl.edu 314-747-1378 http://research.wustl.edu/complianceareas/exportcontrols What is an Export? Release

More information

Export Controls and Cloud Computing: Legal Risks

Export Controls and Cloud Computing: Legal Risks Presenting a live 90-minute webinar with interactive Q&A Export Controls and Cloud Computing: Legal Risks Complying with ITAR, EAR and Sanctions Laws When Using Cloud Storage and Services TUESDAY, APRIL

More information

Export Control Guidelines. Background Information

Export Control Guidelines. Background Information Export Control Guidelines Background Information The University of Notre Dame expects that all personnel, including faculty, staff, visiting scientists, postdoctoral fellows, students, and all other persons

More information

What are export controls?

What are export controls? Export Control What are export controls? Refers to US laws that regulate the distribution to foreign national and foreign countries strategically important products, technology, services, and information

More information

TRADE CONTROL POLICY FEBRUARY 2014

TRADE CONTROL POLICY FEBRUARY 2014 TRADE CONTROL POLICY FEBRUARY 2014 TRADE CONTROL POLICY 2 TABLE OF CONTENT 1 What is trade control? 3 2 What you should know 3 3 Who is affected? 4 4 What you should do 4 4.1 Know your deal items, customers

More information

Table of Contents 762.1 SCOPE 762.2 RECORDS TO BE RETAINED

Table of Contents 762.1 SCOPE 762.2 RECORDS TO BE RETAINED Recordkeeping Part 762--page 1 Table of Contents 762.1 SCOPE... 1 762.2 RECORDS TO BE RETAINED... 1 762.3 RECORDS EXEMPT FROM RECORDKEEPING REQUIREMENTS... 3 762.4 ORIGINAL RECORDS REQUIRED... 4 762.5

More information

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES

Introduction To Commerce Department. Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Introduction To Commerce Department Export Controls U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES Overview The Department of Commerce s Bureau of Industry and

More information

Export Control Regulations Overview. HPHC and HPHCI

Export Control Regulations Overview. HPHC and HPHCI Export Control Regulations Overview HPHC and HPHCI What are Export laws? Export control regulations are federal laws that prohibit the unlicensed export of certain commodities or information for reasons

More information

EU Export Control. December, Johan Dewachter

EU Export Control. December, Johan Dewachter EU Export Control December, 2015 Johan Dewachter Presenter: Johan Dewachter 8 years experience in forwarding operations Works for BDP since 2008 6 years Project Operations Joined Center of Excellence Regulatory

More information

U.S. Export Control Laws

U.S. Export Control Laws U.S. Export Control Laws Holland & Hart International Practice Group Trip Mackintosh July 31, 2001 I. General overview. U.S. export control laws apply to virtually every international transaction. In most

More information

Director of Logistics & Compliance James Hall

Director of Logistics & Compliance James Hall Minimizing Risk Exposure While Fully Utilizing Freight Forwarders Expertise To Effectively Apply Compliance In Challenging Locations Director of Logistics & Compliance James Hall What is Compliance Adherence

More information

Export Control What You Need to Know

Export Control What You Need to Know Export Control What You Need to Know What are export control regulations? US Export control regulations restrict the use of, and access to, certain sensitive or controlled technical information, materials

More information

Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce

Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce Office of Export Enforcement Bureau of Industry and Security (BIS) U.S. Department of Commerce Sidney M. Simon Special Agent in Charge New York Field Office Export Enforcement s Mission Protect National

More information

FCPA, Sanctions, Export, & Antiboycott Compliance

FCPA, Sanctions, Export, & Antiboycott Compliance FCPA, Sanctions, Export, & Antiboycott Compliance Charlie Parker 713-632-8000 Cam Barker 512-533-0150 The Law US PERSONS CANNOT: Bribe foreign government officials FCPA Enter into transactions with Sanctioned

More information

FREIGHT FORWARDER GUIDANCE

FREIGHT FORWARDER GUIDANCE U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT AND COMPLIANCE DIVISION FREIGHT FORWARDER GUIDANCE February 2012 Freight Forwarder Guidance Members

More information

Protecting the Value of Your Transaction y

Protecting the Value of Your Transaction y International Trade Due Diligence: Protecting the Value of Your Transaction y by Megan A. Gajewski, Susan M.C. Kovarovics, Michael D. Mellen and Christina A. Zanette You just closed a deal for your client,

More information

Export Control Laws Briefing

Export Control Laws Briefing Export Control Laws Briefing Academic Department Heads William W. Durgin Associate Provost for Academic Affairs Vice President for Research Export Control Transfer of controlled technology, information,

More information

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY

GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY GOODMAN GLOBAL GROUP, INC. EXPORT CONTROL AND SANCTIONS COMPLIANCE POLICY Goodman Global Group, Inc. and our affiliates (collectively, the Company ) are committed to complying with all laws applicable

More information

Export Controls. How to Comply with Export Controls. By Kimberly Marshall

Export Controls. How to Comply with Export Controls. By Kimberly Marshall Export Controls How to Comply with Export Controls By Kimberly Marshall Purpose of Regulation Technological superiority is a significant element in the defense of the United States, along with research,

More information

SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY

SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 16 EXPORT CONTROL AND ECONOMIC SANCTIONS POLICY Section 1. Purpose... 2 Section 2. Policy Statement and Institution Policies... 2 Section

More information

Policy and Procedures Date: 08-24-11

Policy and Procedures Date: 08-24-11 Virginia Polytechnic Institute and State University Policy and Procedures Date: 08-24-11 Subject: Export and Sanctions Compliance Policy Definitions 1.0 Policy 2.0 Oversight 3.0 Responsibilities of Faculty,

More information

EXPORT CONTROL. What Researchers Need to Know

EXPORT CONTROL. What Researchers Need to Know EXPORT CONTROL What Researchers Need to Know Overview The Basics: Exports, Deemed Exports, Definitions The Export Control Regulatory Framework ITAR, EAR and OFAC Exclusions Penalties Application to University

More information

Middle Tennessee State University. Office of Research Services

Middle Tennessee State University. Office of Research Services Middle Tennessee State University Office of Research Services Procedure No.: ORS 007: Export Control Date Approved: December 08, 2011 1. INTRODUCTION: It is the intent of Middle Tennessee State University

More information

DHL GLOBAL FORWARDING Import Customs Brokerage USA

DHL GLOBAL FORWARDING Import Customs Brokerage USA Trade Lane Management DHL GLOBAL FORWARDING Import Customs Brokerage USA Patrick Demler / Robert Marjai, Chicago December 15 2011 OVERVIEW MODULES 1. USA Import brokerage / CBP and OGA (Other Government

More information

Export Control Training

Export Control Training 2007 Export Control Training Office of Sponsored Research and Programs Missouri State University Missouri State University Research Security and Export Controls Compliance Manual 11/7/2007 1 As an employee

More information

Export Controls. Identifying and supporting export-controlled activities and projects on Grounds

Export Controls. Identifying and supporting export-controlled activities and projects on Grounds Export Controls Identifying and supporting export-controlled activities and projects on Grounds Kelly Hochstetler, Director Email: kjh5e@virginia.edu Phone: 982-5725 Fax: 982-3096 http://www.virginia.edu/sponsoredprograms/exportcontrols.html

More information

Regulatory Compliance and Trade

Regulatory Compliance and Trade Regulatory Compliance and Trade Global Transaction Services Cash Management Trade Services and Finance Securities Services Fund Services Regulatory Compliance and Trade 2007 These materials are provided

More information

the Export Transaction Michael Ford

the Export Transaction Michael Ford Freight Forwarder Roles in the Export Transaction Michael Ford s1 Presenter Michael J. Ford Vice President of BDP International for Regulatory Compliance and Quality Over 31 years of service with BDP working

More information

How to build a great compliance program for your U.S. imports

How to build a great compliance program for your U.S. imports How to build a great compliance program for your U.S. imports For the importer of record, compliance means the complete and accurate recording of all internal processes through books and records, from

More information

COMPLIANCE WITH US TRADE CONTROLS LAWS

COMPLIANCE WITH US TRADE CONTROLS LAWS Statement of Policy COMPLIANCE WITH US TRADE CONTROLS LAWS Villanova University is committed to maintaining an open academic environment, protecting the academic freedom of its faculty and students, and

More information

Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES)

Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES) Export Clearance Requirements Part 758-page 1 Table of Contents 758.1 THE ELECTRONIC EXPORT INFORMATION (EEI) FILING TO THE AUTOMATED EXPORT SYSTEM (AES)1 758.2 AUTOMATED EXPORT SYSTEM (AES)... 5 758.3

More information

OFAC Compliance Overview and

OFAC Compliance Overview and OFAC Compliance Overview and Recent Trends Frederick E. Curry III Deloitte Transactions and Business Analytics LLP November 2014 Institute of International Bankers & Conference of State Bank Supervisors

More information

758.1 THE SHIPPER S EXPORT DECLARATION (SED) OR AUTOMATED EXPORT SYSTEM (AES) RECORD

758.1 THE SHIPPER S EXPORT DECLARATION (SED) OR AUTOMATED EXPORT SYSTEM (AES) RECORD Export Clearance Requirements Part 758-page 1 758.1 THE SHIPPER S EXPORT DECLARATION (SED) OR AUTOMATED EXPORT SYSTEM (AES) RECORD (a) The Shipper s Export Declaration (SED) or Automated Export System

More information

Export Controls and Archeology Research. Marie Hladikova, Export Control Director Office of Research Compliance

Export Controls and Archeology Research. Marie Hladikova, Export Control Director Office of Research Compliance Export Controls and Archeology Research Marie Hladikova, Export Control Director Office of Research Compliance Legal Disclaimer The information contained in this presentation does not constitute legal

More information

If your company participates in the aerospace

If your company participates in the aerospace EXPORT COMPLIANCE: UNDERSTANDING ITAR AND EAR RE-EXPORT Any shipment or transmission of product or technical data from one foreign country to another foreign country. If your company participates in the

More information

Atlantic City March 2014 Michael Ford

Atlantic City March 2014 Michael Ford Reporting and Documentary Requirements under the ITAR Atlantic City March 2014 Michael Ford Objective of this session Understanding the stakeholders The key data elements for Data filing The Logistical

More information

Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY

Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY Export Control Laws Training Presentation FLORIDA INSTITUTE OF TECHNOLOGY 1 Why Be Concerned with Export Control Laws Certain export control laws may apply to FIT research activities here and abroad. Failure

More information

Services Summary TRADITIONAL CUSTOMS SERVICES. Instruments of International Traffic Foreign market entry plans

Services Summary TRADITIONAL CUSTOMS SERVICES. Instruments of International Traffic Foreign market entry plans Services Summary What distinguishes GTS from others is our ability to identify your business needs, customize a practical solution and take the action steps necessary to implement that solution. Our practice

More information

Partners for Trade Seminar Calendar: 2007 2014

Partners for Trade Seminar Calendar: 2007 2014 Spring, 2014 Seminars March Partners for Trade Seminar Calendar: 2007 2014 28 OFAC Webinar Series: An Introduction to U.S. Economic and Trade Sanctions (webinar) April 3 Export School Fast Track Certificate

More information

Trade Software Developer Technical Seminar Automated Export Manifest. William Delansky, CBP Cargo Control and Release March 7, 2012

Trade Software Developer Technical Seminar Automated Export Manifest. William Delansky, CBP Cargo Control and Release March 7, 2012 Trade Software Developer Technical Seminar Automated Export Manifest William Delansky, CBP Cargo Control and Release March 7, 2012 1 CBP ISSUE STATEMENT In order to comply with the provisions of the Safe

More information

Export Management and Compliance Program Guide

Export Management and Compliance Program Guide Export Management and Compliance Program Guide The UAMS Export Management and Compliance Program Guide attempts to provide relevant information about export controls and how they affect the academic and

More information

US Export Regulations Compliance. Presented by Larry Disenhof Cadence Design Systems, Inc.

US Export Regulations Compliance. Presented by Larry Disenhof Cadence Design Systems, Inc. US Export Regulations Compliance Presented by Larry Disenhof Cadence Design Systems, Inc. 1 Agenda Why export regulations? What is an export Compliance process Global operations and compliance Resources

More information

US and EU Ukraine/Russian Sanctions What you need to know for your business Breakfast at Bryan Cave Washington, D.C.

US and EU Ukraine/Russian Sanctions What you need to know for your business Breakfast at Bryan Cave Washington, D.C. US and EU Ukraine/Russian Sanctions What you need to know for your business Breakfast at Bryan Cave Washington, D.C. Tuesday, October 14, 2014 8:30 a.m. to 9:30 a.m Presenters Anita Esslinger Susan Kovarovics

More information

Enterprise Terrorist Financing & Money Laundering Policy

Enterprise Terrorist Financing & Money Laundering Policy Policy Sponsor: Summary: CA and Compliance Sets out obligations under and suggestions for procedures to comply with antiterrorist financing, anti-money laundering and other laws implementing sanctions

More information

Professional Association of Exporters & Importers

Professional Association of Exporters & Importers Professional Association of Exporters & Importers Foreign Trade Regulations & Export Value August 23, 2011 By George R. Tuttle, III George R. Tuttle Law Offices One Embarcadero Center, Suite 730, San Francisco

More information

Export Control Management System

Export Control Management System Export Control Management System Export Controls are federal regulations and laws that restrict the export of certain controlled technologies in order to restrict access to goods and technology that have

More information

Top 10 Questions to Ask Before Exporting Software Containing Encryption

Top 10 Questions to Ask Before Exporting Software Containing Encryption Top 10 Questions to Ask Before Exporting Software Containing Encryption January 14, 2009 Agenda Introduction FOSSBazaar Top Ten Questions Before Exporting Encryption Questions & Answers Speakers Eran Strod

More information

Fundamentals of International Trade Transactions & International Trade Compliance

Fundamentals of International Trade Transactions & International Trade Compliance Fundamentals of International Trade Transactions & International Trade Compliance 1 st Annual International Trade Conference University of Nebraska-Omaha Thompson Center April 12, 2016 INTERNATIONAL CONTRACT

More information

TABLE OF CONTENTS - 2 -

TABLE OF CONTENTS - 2 - Export Control Compliance Program Guidelines December, 2010 TABLE OF CONTENTS Introduction... 3 Institutional Policy... 4 Federal Laws, Regulations, and Penalties... 5 Key Terms and Definitions... 8 Training

More information

EXPORT COMPLIANCE MANUAL

EXPORT COMPLIANCE MANUAL EXPORT COMPLIANCE MANUAL Prepared By: John Fusco of Locke Lord LLP (07/21/2015) Approved By: Rick Parent - Export Compliance Mgr. Revision B TABLE OF CONTENTS Page 1. ASTRO-MED INC. REGULATORY COMPLIANCE

More information

OFAC Compliance Overview and Recent Trends

OFAC Compliance Overview and Recent Trends OFAC Compliance Overview and Recent Trends Frederick E. Curry III Deloitte Transactions and Business Analytics LLP December 2015 Institute of International Bankers & Conference of State Bank Supervisors

More information

INCOTERMS Presented Exclusively for

INCOTERMS Presented Exclusively for INCOTERMS 2010 Presented Exclusively for Why INCOTERMS? Delivery of goods in an export-import transaction requires Using one or more segments of transportation A variety of services to arrange the transportation,

More information

Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes

Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes Doing Business With Iran: Mitigating Risk Exposure Under Canada s Economic Sanctions, Export Controls and Anti-Corruption Regimes John W. Boscariol February 23, 2016 Why This Now Matters to Canadian Companies

More information

Export Controls Compliance

Export Controls Compliance Export Controls Compliance Division of Research The Research Foundation of State University of New York At Binghamton University The purpose of this document is to provide overall guidance on export control

More information

Export Documents. August 15, Philadelphia, PA

Export Documents. August 15, Philadelphia, PA August 15, 2013 Philadelphia, PA Presented by Torsten (Tom) Helk Tom is BDP s Manager Hazardous Materials and Export Compliance, and has been with BDP since 1991. Tom started his career in logistics in

More information

Export Control Compliance Procedure Guide June 8, 2012

Export Control Compliance Procedure Guide June 8, 2012 Export Control Compliance Procedure Guide June 8, 2012 1 TABLE OF CONTENTS Contents TABLE OF CONTENTS... 1 SUMMARY... 2 INTRODUCTION... 3 SCHOOL POLICY... 4 EXCLUSIONS... 4 WHAT IS AN EXPORT?... 4 CONDUCTING

More information

Trade Compliance & Exports

Trade Compliance & Exports Trade Compliance & Exports GETTING MAXIMUM RESULTS WITH LIMITED RESOURCES CREATING A PRACTICAL, RISK-BASED TRADE COMPLIANCE PROGRAM Gwendolyn L. Hassan, JD Manager of Corporate Compliance Office of the

More information

Export Control Management Plan August 2008

Export Control Management Plan August 2008 Export Control Management Plan August 2008 Please direct all inquiries regarding this document to the Export Control Officer, Sponsored Programs Administration Introduction Federal law implements export

More information

DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS

DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS DHL CUSTOMS SERVICES TAKING THE COMPLEXITY OUT OF CUSTOMS Are you fully COMPLIANT? The international trade and compliance landscape is rapidly changing, and global supply chains are facing major challenges.

More information

Credit Investigations and Getting to Know Your Customer. Speaker Ed Bell, PhD, CICP, ICCE Date June 13 th, 2016 Time 3:45 5:00pm Session Number 25030

Credit Investigations and Getting to Know Your Customer. Speaker Ed Bell, PhD, CICP, ICCE Date June 13 th, 2016 Time 3:45 5:00pm Session Number 25030 Credit Investigations and Getting to Know Your Customer Speaker Ed Bell, PhD, CICP, ICCE Date June 13 th, 2016 Time 3:45 5:00pm Session Number 25030 Going Global Series Credit Investigations and Getting

More information

Export Control Compliance Program Guidelines January 2012

Export Control Compliance Program Guidelines January 2012 Export Control Compliance Program Guidelines January 2012-1 - TABLE OF CONTENTS Introduction... 3 Institutional Policy... 4 Federal Laws, Regulations, and Penalties... 5 Key Terms and Definitions... 8

More information

SI/SAO Export Compliance Training 1/9/2014

SI/SAO Export Compliance Training 1/9/2014 1 Why Compliance Matters Risks and Responsibilities Export Controls are Complex Understanding the Regimes and Agencies we must comply with What processes we are putting in place at SI to comply Identifying

More information

Best Practices in Export Compliance: Five Key Issues in Canadian Trade Control Compliance and Enforcement

Best Practices in Export Compliance: Five Key Issues in Canadian Trade Control Compliance and Enforcement Best Practices in Export Compliance: Five Key Issues in Canadian Trade Control Compliance and Enforcement Canadian Association of Importers and Exporters Webinar John W. Boscariol July 16, 2013 Today s

More information

U.S. Economic Sanctions Laws and How They Affect Insurance Brokers

U.S. Economic Sanctions Laws and How They Affect Insurance Brokers U.S. Economic Sanctions Laws and How They Affect Insurance Brokers The United States Government imposes economic sanctions against several countries and a large number of individuals and entities, in response

More information

Tips for Companies Doing Business in Russia and Ukraine Following Russia s Acquisition of Crimea

Tips for Companies Doing Business in Russia and Ukraine Following Russia s Acquisition of Crimea Tips for Companies Doing Business in Russia and Ukraine Following Russia s Acquisition of Crimea by David Townsend, Mike House and Ann Nagele, Perkins Coie LLP 1 Introduction The United States has responded

More information

Using Technology Control Plans in Export Compliance. Mary Beran, Georgia Tech David Brady, Virginia Tech

Using Technology Control Plans in Export Compliance. Mary Beran, Georgia Tech David Brady, Virginia Tech Using Technology Control Plans in Export Compliance Mary Beran, Georgia Tech David Brady, Virginia Tech What is a Technology Control Plan (TCP)? The purpose of a TCP is to control the access and dissemination

More information

Summary of the North Korea Sanctions and Policy Enhancement Act of 2016

Summary of the North Korea Sanctions and Policy Enhancement Act of 2016 Summary of the North Korea Sanctions and Policy Enhancement Act of 2016 February 18, 2016 Less than a week after North Korea s January 6, 2016 nuclear test, the U.S. House of Representatives passed a sanctions

More information

United States Export Controls on Internet Software Transactions. John F. McKenzie Partner, Baker & McKenzie LLP

United States Export Controls on Internet Software Transactions. John F. McKenzie Partner, Baker & McKenzie LLP United States Export Controls on Internet Software Transactions John F. McKenzie Partner, Baker & McKenzie LLP August 2010 Table of Contents 1. Introduction...1 2. The Concept of an "Export" for Export

More information

Managing Third Party Risks in a Global Supply Chain

Managing Third Party Risks in a Global Supply Chain Managing Third Party Risks in a Global Supply Chain The Companies You Keep William Marshall, Hong Kong Ross Denton, London Jasper Helder, Amsterdam Baker & McKenzie Amsterdam N.V. is a member firm of Baker

More information

Guidance To The Commerce Department's REEXPORT CONTROLS. U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services

Guidance To The Commerce Department's REEXPORT CONTROLS. U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services fin BIS Reexport covers 6/14/06 10:13 AM Page 1 Guidance To The Commerce Department's REEXPORT CONTROLS U.S. DEPARTMENT OF COMMERCE Bureau of Industry and Security Office of Exporter Services Guidance

More information

EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION

EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION EXPORT CONTROLS AND RESEARCH AT WPI TRAINING PRESENTATION EXPORT CONTROL LAWS WHAT ARE EXPORT CONTROLS? U.S. laws and their implementing regulations that govern the distribution to foreign nationals and

More information

Using Trade Data to Identify Risk & Opportunity

Using Trade Data to Identify Risk & Opportunity Executives and trade professionals can and should use business information to outthink rivals, and there's no better way to out think them than by using analytics to make superior decisions. This is a

More information

EXPORT CONTROL GUIDELINES FOR STAFF

EXPORT CONTROL GUIDELINES FOR STAFF EXPORT CONTROL GUIDELINES FOR STAFF Created: June 2010 Reviewed: September 2013 Reviewed: April 2015 Maintained by the Office of Sponsored Programs 1 List of Commonly Used Acronyms BIS CCL CJ DDTC EAR

More information

The Exporter s Toolkit: Your Guide to U.S. Government Exporting Resources. Why Export?

The Exporter s Toolkit: Your Guide to U.S. Government Exporting Resources. Why Export? TradeSource Special Edition The Exporter s Toolkit: Your Guide to U.S. Government Exporting Resources July 2012 Issue 5 Why Export? Exporting is a great way to increase your sales and competitiveness!

More information

Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON

Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON Billing Code: 3510-DT-P Department of Commerce Bureau of Industry and Security Action Affecting Export Privileges; ANVIK TECHNOLOGIES SDN. BHD., a/k/a Anvik Technologies; BABAK JAFARPOUR, a/k/a BOB JEFFERSON

More information

CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS

CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS Thomas B. McVey Direct Dial: 202.293.8118 tmcvey@williamsmullen.com CHECKLIST OF COMPLIANCE ISSUES UNDER THE INTERNATIONAL TRAFFIC IN ARMS REGULATIONS By: Thomas B. McVey Williams Mullen June 2, 2014 The

More information

Expanding Internationally with Confidence by Ensuring Global Trade Compliance

Expanding Internationally with Confidence by Ensuring Global Trade Compliance Expanding Internationally with Confidence by Ensuring Global Trade Compliance Justin Cook and Kendra Cook Canopy Consulting International (C2I) jcook@c2iconsulting.com / kcook@c2iconsulting.com www.c2iconsulting.com

More information

Number: M-002 Revision: A Page 1 of 9. Traffic in Arms Regulations (ITAR) MANUAL

Number: M-002 Revision: A Page 1 of 9. Traffic in Arms Regulations (ITAR) MANUAL Page 1 of 9 THIS DOCUMENT IS CONSIDERED UNCONTROLLED UNLESS ISSUED IDENTIFIED AS CONTROLLED Page 2 of 9 REVISION HISTORY DATE CHANGE DESCRIPTION 10/21/09 Original release Approval: Robert Faia Robert Faia,

More information

Export Control Compliance

Export Control Compliance Export Control Compliance OUTLINE: I. Introduction to Export Control Regulations II. III. What Agreements Involve Export Control Regulations? Who must abide IV. Export Control Decision Tree V. Faculty

More information

INTERNATIONAL BUSINESS COMPLIANCE PROGRAMS. By: Thomas B. McVey, Esq.1 Williams, Mullen, Clark & Dobbins Washington, DC TABLE OF CONTENTS

INTERNATIONAL BUSINESS COMPLIANCE PROGRAMS. By: Thomas B. McVey, Esq.1 Williams, Mullen, Clark & Dobbins Washington, DC TABLE OF CONTENTS aáêéåí=aá~äw=omokovpkunnu= íãåîéó]ïáääá~ãëãìääéåkåçã= INTERNATIONAL BUSINESS COMPLIANCE PROGRAMS By: Thomas B. McVey, Esq.1 Williams, Mullen, Clark & Dobbins Washington, DC TABLE OF CONTENTS A. INTRODUCTION

More information