Export Control, Anti-Boycott and Embargo Compliance Policy

Transcription

1 CM.09 1 of 12 1/26/11 New SLC / MWW - 1 Purpose Export Control, Anti-Boycott and Embargo Compliance Policy 1.1 This policy provides mandatory guidance regarding compliance with the export control, anti-boycott and embargo regulations of the United States. Specifically, this policy describes the areas of responsibility for employees of Laserage Technology Corporation and any current and/or future affiliate or subsidiary, (collectively, Laserage or the Company ) to ensure compliance with the US Government ( USG ) statutes and regulations pertaining to the following: (i) export of controlled products, services and technology; (ii) compliance with US-sanctioned boycotts of other countries, and the parallel requirement not to participate in prohibited boycotts; and (iii) compliance with regulations pertaining to transactions with prohibited parties. 1.2 USG statutes and regulations impose strict requirements on the export of certain products, services and technology from the United States, the re-export of US-origin products and technology (and the direct product thereof) from foreign destinations, and the import of certain products addressed herein. This policy requires that employees carefully adhere to these requirements. Failure to do so can result in severe penalties being imposed on the Company, including expensive fines and revocation of exporting privileges. Employees who fail to take the necessary measures to ensure compliance with all export control, anti-boycott and embargo requirements addressed herein will be subject to disciplinary action. 2 Application 2.1 This policy applies to all Laserage divisions and departments, employees and contracted independent Sales Representatives and shall be complied with in the course of doing business in international markets or with foreign persons or companies in or outside of the United States. 2.2 While this policy prescribes Company-wide compliance with the regulations referenced in paragraph 4.1 below, it is not designed as or intended to be a primer or a compendium of those regulations. The regulations referenced in paragraph 5.1 below or their relevant interpretation or applicability to a particular Company circumstance may be obtained from the Company s outside expert counsel through one of the responsible Company officials described in Section 4. 3 Definitions Refer to Appendix A 4 Responsibilities 4.1 Overall export control, anti-boycott and embargo compliance for Laserage shall be the responsibility of the Chief Executive Officer ( CEO ), who shall ensure the appointment of other designated responsible individuals. 4.2 Overall adherence to this policy and the implementation of related procedures (see SOP.10) shall be the responsibility of the Chief Financial Officer ( CFO ), who shall report directly to the CEO. The CFO shall, on an ongoing basis, monitor the export control, anti-boycott and embargo compliance activities of the Company and adherence to this policy and implementing procedures by all subsidiaries or affiliates. The CFO shall also serve as the Department of State ( DOS ) Empowered Official for Laserage International Traffic in Arms Regulations ( ITAR ) compliance. 4.3 As necessary, a Local Export Control Manager ( LECM ) shall be appointed by the CEO, who will have responsibility for export control, anti-boycott and embargo compliance at the local level at each discrete Laserage facility, including each Laserage subsidiary or affiliate. The LECM shall closely coordinate export functions with the CFO in support of overall export control, antiboycott and embargo compliance. The LECM shall ensure that at least annually, selected portions of policy and procedural compliance are included in an internal audit. The CFO shall

2 CM.09 2 of 12 1/26/11 New SLC / MWW - coordinate with the LECM at least quarterly in order to remain appraised of the status of overall compliance with this Corporate Policy and with regard to any changes in applicable law or regulation. 4.4 Every Laserage employee with job responsibility for dealing with international business matters, in any capacity, shares responsibility for adherence to this policy and implementation of related procedures. If any employee of the Company has a question concerning the applicability of this policy or related procedures to any given international activity or transaction, he or she has an affirmative obligation to contact either the CFO or the applicable LECM for clarification. 5 Associated Documents 6 Policy 5.1 Applicable USG regulations: The Export Administration Regulations ( EAR ) of the US Department of Commerce ( DOC ); The International Traffic In Arms Regulations ( ITAR ) of the US Department of State ( DOS ); The anti-boycott and embargo provisions of the DOC and DOS; The anti-boycott and embargo provisions of the US Department of the Treasury ( DOT ), Office of Foreign Assets Control ( OFAC ); and For ease of reference, a listing of relevant acronyms is attached to this policy as Appendix A. 5.2 Export Control (SOP.10) 6.1 Laserage requires that all of its employees and agents conduct Company business in conformance with the highest possible ethical standards. 6.2 Laserage requires that all of its employees and agents conduct Company business in conformance with the statutes, decrees, regulations, guidelines, and policies of both the USG and the foreign government in those countries in which the Company operates, as applicable in any given transaction. 6.3 Laserage employees and agents working in the international business arena should be fully familiar with the USG export control, anti-boycott and embargo regulatory requirements listed in section 5.1 above. Laserage recognizes that not all of these regulations are applicable to every international transaction. However, given the variety of international transactions conducted by the Company, each employee with job responsibilities in the international business arena must have a working knowledge of the broad requirements of these regulations. 6.4 Federal export laws are complex and some of the Company s products (including services and technology/technical data), and some products sourced from vendors by the Company for its own projects, shall require special licenses or other authorizations before such products or technology may be legally exported or otherwise taken out of the country (including taken on business travel or returned to a foreign supplier for repair). In addition, the importation of certain products by Laserage may require a license or other authorization, as will the employment by Laserage of any foreign nationals in certain positions. Licensing requirements depend, in part, upon the type of product or technology exported or imported, the parties and countries of destination and the ultimate distribution of products or technology.

3 CM.09 3 of 12 1/26/11 New SLC / MWW The following are the processes by which Laserage shall comply with USG export control, anti-boycott and embargo regulatory requirements for export shipments: Embargo Screening. Due to US trade embargoes administered by the DOC, DOS and DOT, no transaction relating to the sale of products, services or technology may be entered into with companies in any embargoed country, companies or individuals based in embargoed countries (regardless of ship-to address), governments of embargoed countries (regardless of ship-to address), and nationals of embargoed countries (regardless of ship-to address). To ensure compliance, the CFO and all LECMs shall maintain a current list of all embargoed countries Boycott Screening. It is unlawful for US companies to participate in or comply with foreign boycotts which are not supported by the USG. The Arab League boycott of Israel is the principal foreign economic boycott that US companies must be concerned with today. The anti-boycott laws, however, apply to all boycotts imposed by foreign countries that are unsanctioned by the United States Specifically, the following types of conduct are deemed unlawful: (a) agreements to refuse or actual refusal to do business with or in Israel or with blacklisted companies; (b) agreements to discriminate or actual discrimination against other persons based upon race, religion, sex, or national origin; (c) agreements to furnish or actual furnishing of information about business relationships with or in Israel or with blacklisted companies; (d) agreements to furnish or actual furnishing of information about the race, religion, sex, or national origin of another person; and (e) implementing letters of credit containing prohibited boycott terms or conditions: All prohibited boycott-related requests must be immediately reported to the CFO in order to: (a) determine whether USG agencies must be notified, specifically the DOC and the DOT; and (b) to make all mandatory reports within the mandated time constraints set down by those USG agencies Once a prohibited boycott-related request is received, no transaction of any kind with the requesting party may take place without the prior written authorization of the CFO Customer Screening. All customers, potential customers or other entities receiving international shipments from the Company, including US and foreign intermediaries such as consignees, agents, brokers and freight forwarders, must be checked by the Company against the various export control, anti-boycott and embargo lists of prohibited parties. The applicable Business Unit Manager or department Manager (the Manager ) shall be responsible for ensuring all such parties are screened against these listings prior to authorizing shipment and shall coordinate with the LECM, as necessary, to ensure that such screening has been performed. If the screening is conducted by an outside vendor or software, the LECM shall ensure that all screening results are reviewed and any outstanding results be resolved prior to proceeding with the transaction. If the LECM discovers that a party to the transaction is on one of the prohibited lists, the LECM is empowered to stop shipment and shall immediately inform the CFO. A record of each screening shall be maintained by the LECM for a period of five (5) years, as required by applicable regulation. The USG lists are as follows: United States Department of Commerce ( DOC ) (i) Denied Persons: No export transactions may be entered into with a person or entity subject to a DOC denial order, which not only denies parties the right to

4 CM.09 4 of 12 1/26/11 New SLC / MWW - export from the US, but also prohibits third parties from dealing with them in export transactions involving US items. The DOC maintains the Denied Persons List at (ii) Prohibited Entities: No export transactions may be entered into with a person or entity listed on the DOC s Entity List, which includes private and governmental organizations which are known to engage in prohibited weaponsproliferation activities. The DOC maintains the Entity List at (iii) Unverified Parties: The DOC s Unverified List includes foreign persons who in the past were parties to a transaction with respect to which the DOC could not conduct a check or verification. Any transaction to which a listed person is a party will be deemed by the DOC as a red flag. The Unverified List is at (iv) General Orders: The DOC also imposes certain restrictions in the EAR in the form of General Orders in Part 736 of the EAR, Supplement No. 1. For example, General Order No. 3 of June 5, 2006 and revised on September 6, 2006, imposes a license requirement for export and re-export transactions involving all items subject to the EAR where the transaction involves any of the specific entities or individuals named therein. It also prohibits the use of License Exceptions found in the EAR for exports or re-exports of any items subject to the EAR involving these specifically named entities and individuals. DOC has indicated that it intends to issue additional General Orders in the future imposing license requirements for export and re-export transactions subject to the EAR to specific entities and individuals that will not be added to the other DOC lists named above, which list is maintained at United States Department of the Treasury ( DOT ) lists of Specially Designated Individuals and Entities: No export transaction may be entered into with a person or entity designated as any one of the following by the DOT: Specially Designated National ( SDN ), Specially Designated Terrorist ( SDT ), Specially Designated Global Terrorist ( SDGT ), Foreign Terrorist Organization ( FTO ), Specially Designated Narcotics Trafficker ( SDNT ), or Blocked Person ( BP ). The names of these individuals and organizations are maintained by the DOT to identify persons and entities determined to have committed, or to pose a significant risk of committing, acts of terrorism, narcotics traffickers, or those affiliated with countries and organizations subject to US trade embargoes. The names of the individuals and entities so designated are posted together at The list is organized alphabetically, and each individual s particular category/designation is noted at the end of his name United States Department of State ( DOS ) List of Debarred Parties:

5 CM.09 5 of 12 1/26/11 New SLC / MWW - No export transaction may be entered into with a party denied export privileges on the list maintained by the DOS Directorate of Defense Trade Controls at General Services Administration ( GSA ) Debarred Bidder List/Excluded Parties List: No transaction related to a Government contract may be entered into with a party who has been debarred, suspended or deemed ineligible. The List is maintained by the GSA at Product Classification. The Manager is primarily responsible for obtaining the appropriate export classifications (the ECCN and the HT code) for each export under his or her control. If requested, the LECM can obtain an export classification or assist in the determination of a classification in accordance with applicable export control regulations, however, the Manager is responsible for ensuring such classifications have been (or are likely to be) received prior to proceeding with any transaction At the time an export order is placed, the Manager shall be responsible for ensuring that each customer placing an order, whether purchaser or ultimate end-user, provides Laserage the proper export jurisdiction (specifically, the final re-export destination, if any, and the end use) of the ordered item, as well as any technical data necessary for making a classification determination The LECM shall be responsible for maintaining an Export Classification Matrix pertaining to Laserage product export classifications. Whenever possible, the USML Categories and ECCNs shall be obtained from the purchaser or ultimate end-user, as indicated in this Section , however, when the customer fails to provide that data, the Manager, in coordination with the LECM, may apply the most applicable classification from the Export Classification Matrix. (i) The Export Classification Matrix shall delineate each of Laserage s routinely manufactured general categories of products and any significantly recurring customer-specific products. Each entry shall include: the DOS US Munitions List ( USML ) Categories (if any) applicable to the products, services or technology; the applicable DOC s Export Control Classification Numbers ( ECCN ); the corresponding Schedule B or Harmonized Tariff Schedule numbers; and, when applicable, relevant license data (license number, end destination and expiration date) or license exceptions or exemptions for applicable countries or country groups. (ii) Laserage employees involved in sales, marketing, quoting, order management and purchasing (when processing items for repair, which shipment thereof constitutes an export) shall be responsible for referring to the Export Classification Matrix as well as to this policy in the course of their duties with regard to all relevant transactions Existing Export Customers/Products vs. New Export Customer/Products. All recurring existing export customers and their export products will be screened in accordance with Section above by the LECM and the CFO and an entry made in the Export Classification Matrix indicating that Managers are free to proceed with export shipments of delineated products to those delineated customers, but only in accordance with the data (including any restrictions) shown in the Export Classification Matrix. New export customers or new export products (including new products to existing export customers) must be screened and approved as follows:

6 CM.09 6 of 12 1/26/11 New SLC / MWW The Manager of the department contemplating the export, after initiating action to obtain the export classifications (Section above), is responsible for ensuring that the CFO and the LECM are notified as soon as an order has been initiated by a foreign entity or for ultimate end-use in a foreign destination. The CFO is responsible for final determination of all export control classifications provided by the customer or ultimate end-user. When necessary, the CFO shall consult with outside export legal counsel to confirm export classification information provided by a customer or ultimate end-user. When appropriate, the CFO shall submit (or shall direct the LECM to submit, with or without the assistance of outside expert counsel), a commodity classification request to the DOC or a commodity jurisdiction request to the DOS for review The CFO and Manager will determine the likelihood of recurrence of the export transaction and, if appropriate, the CFO will direct the LECM to add the New Customer and/or New Products to the Export Classification Matrix The CFO is responsible to monitor changes to applicable USG. The CFO will review and update as needed any previous export control classifications Order Entry and Shipping Procedures. The applicable Manager shall be responsible to clear each item for export prior to shipment. In this context, the term order can mean purchase order, request for quote or proposal, invitation to bid, marketing projects and presentations, product demonstrations, and similar means that can result in the company making an export. The applicable Manager shall evaluate the risk of and use his or her own business judgment to determine whether or not to accept an order (and subsequently begin work on that order) prior to establishing that the resulting shipment will be able to obtain export clearance Additional Export/Import Transactions. Each Manager shall, in a timely manner, inform the CFO of any of the following contemplated non-order related, but possibly export regulated transactions: Visits By Non-US Person. The CFO shall be notified in advance of any contemplated visit to Laserage by a person who is not a US citizen or permanent resident alien. The Laserage employee involved with the visit will provide all information requested by the CFO or LECM to permit them to properly evaluate the export control implications of the visit and obtain any export authorizations required. Visitors in these categories, who have not been pre-screened, including unannounced visitors, may be denied facility access or may be granted only highly restricted access Non-US Employment Candidates. The CFO shall work with Laserage s Human Resources department to ensure that all hiring procedures comply with the export control regulations identified herein and to ensure that the export control implications of any new hire are properly considered Import of USML Items. The CFO should be notified of any intention to import items on the USML into the US to ensure any and all authorizations are obtained in a timely fashion Destination Control Statements. Shipment documentation shall contain the proper, current destination control statement: For commodities subject to the EAR, the CFO shall ensure that the following Destination Control Statement appears on all copies of shipping documentation, including the bill of lading and commercial invoice:

7 CM.09 7 of 12 1/26/11 New SLC / MWW - These commodities, technology, or software were exported from the United States in accordance with the Export Administration Regulations. Diversion contrary to US law prohibited (EAR Section 758.6) For commodities subject to the ITAR, the CFO shall ensure that the following Destination Control Statement appears on all copies of shipping documentation, including the bill of lading and commercial invoice, or any other language, as applicable: These commodities are authorized by the US Government for export only to [insert country of ultimate destination] for use by [insert name of end user]. They may not be transferred, transshipped on a noncontinuous voyage, or otherwise be disposed of in any other country, either in their original form or after being incorporated into other end-items, without the prior written approval of the US Department of State. 7 Records 7.1 Automated Export System ( AES ) Entries. Under certain conditions, an AES entry is required by the USG of the US Census Bureau, US Customs and Border Protection, and/or under both EAR and ITAR. Such an entry was formerly known as a Shippers Export Declaration ( SED ), particularly when such entries were submitted on paper and SED paperwork would accompany the shipment. Currently AES entries are more often referred to as Electronic Export Information ( EEI ). Specific EEI requirements differ from regulation to regulation. The CFO shall ensure systems/procedures are in place to guide Laserage and/or its freight forwarders in entering required EEI into AES. 7.2 Recordkeeping. Export control regulations contain requirements regarding the retention of export documentation. The LECM, in coordination with the CFO, shall be responsible for the maintenance of a central records file for the Company for this documentation, which shall be retained in accordance with the Records Retention Policy (CM.15). 8 Attachments Appendix A EAR/ITAR Acronyms and Definitions Appendix B ECCN Numbering System Appendix C US Munitions List (USML) Categories 9 Flow Chart None

8 CM.09 8 of 12 1/26/11 New SLC / MWW - APPENDIX A EAR/ITAR Control Acronyms and Definitions AECA AES BIS BP CCL DDTC DOC DOT DLP DPL DOD DSP-5 EAR EEI ECCN The Arms Export Control Act of 1976, which gives the President of the United States (and, therefore, the Executive Branch, including the Department of State) the authority to control the import and export of defense articles and defense services The US Census Automated Export System, which is the electronic (Internet-based) way to electronically file an Shipper's Export Declaration (SED) and ocean manifest information directly with US Customs Bureau of Industry & Security, the DOC agency responsible for implementing and enforcing EAR and advancing US national security, foreign policy and economic objectives by ensuring an effective export control and treaty compliance system to promote continued US strategic technology leadership Blocked Person, a special subcategory of SDN, which may be a person to whom a USPPI may not export simply because the BP previously failed to fully cooperate with an EAR investigation Commerce Control List, a list governed by Supplement No. 1 to Part 774 of the EAR, maintained by the BIS, which includes items (i.e., commodities, software, and technology) subject to the export licensing authority of BIS Directorate of Defense Trade Controls, the Department of State agency with ITAR oversight Department of Commerce Department of the Treasury Data Loss Prevention, systems or techniques to safeguard against the inappropriate (unlawful) export of technical data or technical violations (violations include the exporting of data without appropriate license, improper reporting and inadequate record keeping) Denied Persons List, a list maintained by the BIS of individuals with whom Laserage may not participate in an export or re-export transaction subject to the EAR because the listed person has had their export privileges denied by the BIS Department of Defense A DDTC form, comprising an Application/License for Permanent Export of Unclassified Defense Articles and Related Unclassified Technical Data. Also used to seek authorization to employ a foreign national in the United States who will have access to the technical data related to defense articles or services (considered an export under the ITAR rules). Export Administration Regulations, regulations that govern the export and re-export of most commercial items. The items that the BIS regulates are often referred to as dual-use, items that have both commercial and military or proliferation applications, but purely commercial items without an obvious military use are also subject to the EAR. Under EAR, an export is defined as any item that is sent from the US to a foreign destination, including tangible products, services, software or technology (which includes technical information or technical data). Electronic Export Information, referring to SEDs which are filed electronically with the US Census through AES, either by the exporter or by a shipper on the exporter s behalf Export Control Classification Number, an alpha-numeric classification used in the (Department of) Commerce Control List to identify items for export control purposes

9 CM.09 9 of 12 1/26/11 New SLC / MWW - FTO GPO GSA HS HTS ITAR LECM NLR NTIS OAC OFAC PM/DDT C SED that describes a particular item or type of item, and shows the controls placed on that item. An ECCN is different from a Schedule B number, which is used by the Bureau of Census to collect trade statistics. It is also different from the HTS Nomenclature, which is used to determine import duties. Foreign Terrorist Organization, a special subcategory of SDN Government Printing Office. Among the many documents the GPO provides (both in print and electronically) are both the CCL and ECCN listings and definitions. Government Services Administration, a government agency that maintains Debarred Bidder and Excluded Party Lists due to past legal or contractual violations The Harmonized System, more accurately the Harmonized Commodity Description and Coding System of tariff nomenclature, which is an internationally standardized system of names and numbers for classifying traded products developed and maintained by the World Customs Organization (WCO) (formerly the Customs Cooperation Council), an independent intergovernmental organization with over 170 member countries based in Brussels, Belgium The Harmonized Tariff Schedule of the United States, which is the primary resource for determining tariff classifications for goods imported into the United States and which can also be used in place of Schedule B for classifying goods exported from the United States International Traffic in Arms Regulations, Federal regulations promulgated and controlled by the DDTC for the control of the manufacture and export of defense articles and services Local Export Control Manager, the individual at each Laserage location responsible for monitoring export control, anti-boycott and embargo compliance activities No License Required, the code put on export documents when either the items are not on the CCL (i.e. EAR99) or the items are on the CCL but there is no X in the box on the Country Chart under the reason for control column on the row for the country of destination National Technical Information Service, an agency of the DOC serving as a central resource for government-funded scientific, technical, engineering and business related information (350 subject areas, including export controls) Office of Anti-Boycott Controls, a BIS agency concerned with regulating and ensuring that US exporters do not engage in USG-deemed illegal international boycotts Office of Foreign Assets Control, an DOT agency that enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of WMD and other threats to the national security, foreign policy or economy of the US Bureau of Political-Military Affairs, a branch of the DDTC, DOS, concerned with registrations of US manufacturers and/or exporters of defense articles and services Shipper s Export Declaration, a filing generally required by the US Census Bureau for daily US exports of a single commodity with a value exceeding US$ 2,500. All SED information is provided to the US Census Bureau and is used for export compliance and governmental reporting. The term SED is somewhat out-dated as it formerly referred to paper submissions and now all submissions must be done electronically (EEI). Technically, however, the data that is filed electronically in AES, either by the exporter or by a consignee on the exporter s behalf, still constitutes an SED

10 CM of 12 1/26/11 New SLC / MWW - SDN SDNT SDGT SDT SNAP-R STELA TAA US USG USML USPPI WMD Specially Designated Nationals, as in the SDN and BP List, a listing of OFAC sanctioned individuals and countries against which export activity must be screened Specially Designated Narcotics Trafficker, a special subcategory of SDN Specially Designated Global Terrorist, a special subcategory of SDN Specially Designated Terrorist, a special subcategory of SDN Simplified Network Application Process Redesign, an Internet-based software solution offered by the BIS, which offers exporters the ability to manage license applications, attach supporting documentation and manage user access rights and which offers BIS Licensing Officers the ability to view work items and supporting documents electronically. [This is the system for which each of the 4 LTC corporate officers have received login ID s and PIN # s.] System for Tracking Export License Application, an automated telephone call-in system (at ) using the Application Control Number printed on the application form Technical Assistance Agreement, an agreement covering the cross-border transfer (including, potentially, the transfer to foreign nationals within the US) of technical data that is subject to EAR (and potentially ITAR, depending on the technical data) United States United States Government US Munitions List, Dept of State, DDTC ITAR Part 121 which designates defense articles and services (both for manufacture and/or export). To the extent that a US entity engages in either the manufacture or the export of any of these items (or parts or components therefor), it must register (be assigned a PM/DDTC number) and pay an annual fee (currently $2,250) US Principal Party of Interest, the entity initiating an export and ultimately responsible for ensuring EAR/ITAR compliance of that export (Laserage, for our exports) Weapons of Mass Destruction (typically nuclear, biological or chemical)

11 CM of 12 1/26/11 New SLC / MWW - APPENDIX B ECCN Numbering System 1. The Commerce Control List (CCL) is organized by Export Control Classification Number (ECCN). 2. An ECCN generally* consists of 5 digits (e.g. 3A001) with the following structure: A. The first number (0 thru 9) represents 10 Categories (see 3 below) B. The second letter (A thru E) represents recurring Product Groups (see 4 below) C. The last 3 numbers (000 thru 999) represent the Reason for Control (see 5 below) D. *The one exception to this numbering scheme is the general EAR99. Any export that cannot be otherwise categorized in the CCL gets the ECCN EAR ECCN Structure the 1 st digit, Categories: 0. Nuclear materials, facilities & equipment and miscellaneous 1. Materials, chemicals and microorganisms & toxins 2. Materials processing 3. Electronics design, development and production 4. Computers 5. Telecommunications and information security 6. Sensors and lasers 7. Navigation and avionics 8. Marine 9. Propulsion systems, space vehicles and related equipment 4. ECCN Structure the 2 nd digit, Product Groups: A. Equipment, assemblies and components B. Test, inspection and production equipment C. Materials D. Software E. Technology 5. ECCN Structure the final 3 digits, Reason for Control Numbering System: National Security Missile Technology Nuclear Nonproliferation Chemical and Biological Foreign Policy: Short Supply and Crime Control Anti-Terrorism / United Nations

12 CM of 12 1/26/11 New SLC / MWW - APPENDIX C US Munitions List (USML) Categories Category I II III IV V VI VII VIII IX X XI XII XIII XIV XV XVI XVII XVIII XIX XX XXI Description Firearms, Close Assault Weapons, Combat Shotguns Guns and Armaments Ammunition and Ordnance Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs and Mines Explosives and Energetic Materials, Propellants, Incendiary Agents and Their Constituents Vessels of War and Special Naval Equipment Tanks and Military Vehicles Aircraft and Associated Equipment Military Training Equipment and Training Protective Personnel Equipment and Shelters Military Electronics Fire Control, Range Finder, Optical and Guidance and Control Equipment Auxiliary Military Equipment Toxicological Agents, Including Chemical Agents, Biological Agents and Associated Equipment Spacecraft Systems and Associated Equipment Nuclear Weapons, Design and Testing Related Items Classified Articles, Technical Data and Defense Services Not Otherwise Enumerated Directed Energy Weapons [Reserved] Submersible Vessels, Oceanographic and Associated Equipment Miscellaneous Articles

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