Virginia Conference On World Trade ITAR COMPLIANCE

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1 Virginia Conference On World Trade ITAR COMPLIANCE R. Ellen Coley ReavesColey PLLC office mobile

2 Objectives To provide instruction on the International Traffic in Arms Regulations ( ITAR ) To provide guidance on ways to avoid ITAR violations

3 Why Does ITAR exist? National Security Anti-Terrorism Weapons Controls Crime Control Non-Proliferation

4 U.S. Export Control Laws ITAR- International Traffic in Arms Regulations United States Munitions List (USML) EAR- Export Administration Regulations Commerce Control List (CCL)

5 Who is subject to ITAR? Any person subject to the jurisdiction of the United States who, as principal or agent (including a forwarding agent), participates in an export transaction

6 What is controlled by ITAR? Items (plus technical data and software) listed on the United States Munitions List ( USML ) Items specifically designed, developed, configured, adapted or modified for a military application (intended use does not matter) Services related to items on the USML

7 What does it mean to Export? Actual shipment or transmission of items out of the United States Release of technology or software subject to the ITAR to a foreign national in the United States

8 What does it mean to Re-export? Actual shipment or transmission of items subject to the ITAR from one foreign country to another foreign country

9 What is a Deemed Export? Transfers of technology (even within the U.S.) to a foreign national are deemed as an export to the foreign national s home country All deemed exports subject to ITAR require a license Watch out for plant visits, negotiations, and employees (Form I-129 Certification)

10 Foreign Nationals NOT a U.S. citizen or lawful permanent resident (green card holder) In the U.S. on a temporary visa

11 Technical Data and Software If the item is controlled, then any technical data and software related to the product is also controlled Examples: - Technical drawings - Operating Manuals - Training Manuals

12 Exporting Technical Data and Software Ship it out of the U.S. Travel out of the U.S. and talk about the technical data and/or software Transmissions out of the U.S. (phone call, fax, ) Foreign national has access

13 Restricting Access Internal control plan for restricting access Visitor sign-in (state citizenship) Locked doors/file cabinets Do not leave technical data visible to the open public

14 ITAR Controlled Registration requirements - Renew yearly Must obtain a license prior to exporting - DTRADE Must inform employees about the terms and conditions of the license

15 EAR Restricted Review the Commerce Control List Depending on what country it will be exported to, the export may require a license EAR 99- No license required to a particular country (unless general prohibitions apply)

16 Licensing of Technical Data Technical Data - Technical proposals (drawings & specs) - Follow-up discussions Office/Plant Visits Foreign national employees

17 What if the Item does Export item unless: NOT Require a License? The end user is a prohibited person or entity The country of destination is under an embargo You have knowledge of an impending violation

18 Screening Screen each customer Denied persons list Specially Designated Nationals list Documentation

19 Check the Country of Final Destination Is it an embargoed country? Cuba, Iran, Iraq, North Korea, Sudan, Syria Re-exports - check the country of FINAL destination even if it will be shipped through another foreign country first

20 Watch out for Red Flags The customer or its address is similar to one of the parties found on the Commerce Department's [BIS's] list of denied persons. The customer or purchasing agent is reluctant to offer information about the end-use of the item. The product's capabilities do not fit the buyer's line of business, such as an order for sophisticated computers for a small bakery.

21 Watch out for Red Flags The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry. The customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing. The customer has little or no business background.

22 Watch out for Red Flags The customer is unfamiliar with the product's performance characteristics but still wants the product. Routine installation, training, or maintenance services are declined by the customer. Delivery dates are vague, or deliveries are planned for out of the way destinations. A freight forwarding firm is listed as the product's final destination. The shipping route is abnormal for the product and destination. Packaging is inconsistent with the stated method of shipment or destination. When questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, for export, or for re-export.

23 ITAR Certificates Government contractors may request an ITAR certificate from their vendors and subcontractors It may be broad, but do NOT over-certify ITAR registration Compliance program

24 ITAR Violations Fines - Up to $1,000,000 per violation Criminal - Up to ten (10) years imprisonment (can prosecute company, officers and directors, and employees) Denial of export privileges Barred from working on government contracts

25 Compliance Plan Management commitment - Management Policy Statement - Reviewed and Signed every year

26 Compliance Plan Written guidelines Polices and procedures Review the handbook Identify the Compliance Team Handbook will be maintained by the Compliance Team

27 Compliance Plan Compliance Training Annual training for all employees - on-line classes - in-house seminars - external seminars Training for all new export personnel

28 Compliance Plan Cradle to Grave Export Compliance Security The Compliance Team will manage the EMCP Document the entire process

29 Compliance Plan Recordkeeping Requirements 5 year retention period All records should be easily retrievable for any given export transaction

30 Compliance Plan Export Compliance Monitoring & Auditing Identify violations/problems Corrective measures

31 Compliance Plan Recordkeeping Requirements 5 year retention period All records should be easily retrievable for any given export transaction

32 Compliance Plan Guidelines for Handling & Reporting Export Violations/Problems Employees should discover and report violations and problems Anonymous reporting

33 Questions/ Contact Information R. Ellen Coley ReavesColey PLLC office mobile

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