Virginia Conference On World Trade ITAR COMPLIANCE
|
|
- Brett Melvyn Cunningham
- 7 years ago
- Views:
Transcription
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
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 informationTRADE 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 informationHarvard 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 informationGOODMAN 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 informationExport 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 informationA 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 informationEXPORT 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 informationMiddle 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 informationIntroduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance Program (ICP) Contracting Services to Outside Experts
Olga Torres, Associate Ol T A i t Braumiller Schulz LLP International Trade Law www.globaltradelaw.net Overview Introduction to Braumiller Schulz LLP Why Trade Compliance? Establishing an Internal Compliance
More informationUS 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 informationUniversity of Maryland Export Compliance Program
April 6, 2015 Message from the Vice President for Research Export control is governed by a group of federal regulations intended to advance the national security, foreign policy, and economic interests
More informationPolicy 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 informationOffice 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 informationUniversity 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 informationExport 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 informationExport 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 informationSecond 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 informationEXPORT 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 informationMastering 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 informationIntroduction 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 informationProtecting 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 informationCredit 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 informationSYSTEM 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 informationFREIGHT 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 informationEXPORT 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 informationUNIVERSITY OF CHICAGO/EXPORT CONTROL PROCEDURES. 1. Background. 2. Export Control Oversight: Who Is Responsible. 3. Jurisdiction and Classification
UNIVERSITY OF CHICAGO/EXPORT CONTROL PROCEDURES 1. Background 2. Export Control Oversight: Who Is Responsible 3. Jurisdiction and Classification 4. End User Screening Against U.S. Government Watch Lists
More informationTHE UNIVERSITY OF ALABAMA IN HUNTSVILLE. EXPORT COMPLIANCE PROGRAM MANUAL Updated August 2012
THE UNIVERSITY OF ALABAMA IN HUNTSVILLE EXPORT COMPLIANCE PROGRAM MANUAL Updated August 2012 List of Abbreviations AECA Arms Export Control Act ATF/BATF Bureau of Alcohol, Tobacco, Firearms & Explosives
More informationExport 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 informationExport 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 informationKey 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 informationDeemed Exports and the Export Control Reform Initiative. Bernard Kritzer Director Office of Exporter Services. July 24, 2013.
Deemed Exports and the Export Control Reform Initiative Bernard Kritzer Director Office of Exporter Services July 24, 2013 Agenda Bernard Kritzer Director Office of Exporter Services Introduction Stephen
More informationUsing 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 informationRegulatory 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 informationExport 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 informationSupplier Awareness. Export Control/ ITAR
Export Control & ITAR Supplier Awareness Export Control/ ITAR THIS INFORMATION IS PROVIDED BY PAR SYSTEMS, INC. ("PAR"). PAR IS NOT A LAW FIRM, AND THE INFORMATION CONTAINED HEREIN IS NOT INTENDED TO BE
More informationExport Control Basics
Export Control Basics Updated on May 15, 2014 What are Export Controls? U.S. laws and regulations that restrict the distribution to foreign nationals and foreign countries of strategically important products,
More informationTable of Contents 734.1 INTRODUCTION 734.1 INTRODUCTION... 1 734.2 IMPORTANT EAR TERMS AND PRINCIPLES... 1 734.3 ITEMS SUBJECT TO THE EAR..
Scope of the Export Administration Regulations Part 734 - page 1 Table of Contents 734.1 INTRODUCTION... 1 734.2 IMPORTANT EAR TERMS AND PRINCIPLES... 1 734.3 ITEMS SUBJECT TO THE EAR.. 4 734.4 DE MINIMIS
More informationTop 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 informationExport 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 informationInternational Traffic in Arms Regulations (ITAR): Who must comply, what is controlled and where do we go from here?
International Traffic in Arms Regulations (ITAR): Who must comply, what is controlled and where do we go from here? Lisa Bencivenga President Lisa Bencivenga, LLC February 20-22, 2013 Orlando World Marriott
More informationUnited 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 informationU.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 informationPolicy on Export of Physical and Intellectual Property Export Controls
~y.~@ Foundation for Tne State U "Ilvtl'S' V ~f NaN YOI< College of OptoInetry Policy on Export of Physical and Intellectual Property Export Controls Date: 04/26/2012 Revision: 1.01 Purpose and preamble
More informationAn ITAR Primer for Small Business Presentation to NDIA Small Business Division Breakfast Meeting Wednesday, September 29, 2010 By Rob Evers Member, NDIA International Division Board What a Challenge! Like
More informationEXPORT 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 informationThis Policy supersedes the Terex Corporation Policy on Transactions in Iran, dated June 7, 2013.
TEREX CORPORATION POLICY REGARDING TRANSACTIONS IN IRAN (the Policy ) applies to all Terex operations and Terex team members worldwide. This Policy supersedes the Terex Corporation Policy on Transactions
More informationExport Compliance Program Policies and Procedures Manual. Office of Research and Economic Development University of Wyoming
Page 1 of 37 Export Compliance Program Policies and Procedures Manual Office of Research and Economic Development University of Wyoming Office of Research and Economic Development Dept. 3355, 1000 University
More informationImplementing Catch All Controls A Risk Assessment-based Approach Toward Nonproliferation
Implementing Catch All Controls A Risk Assessment-based Approach Toward Nonproliferation Mr. Dennis Krepp Office of National Security and Technology Transfer Controls U.S. Department of Commerce March
More informationSI/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 informationEXPORT CONTROLS The Challenge for U.S. Universities. Julie T. Norris (ret.) Office of Sponsored Programs Massachusetts Institute of Technology
EXPORT CONTROLS The Challenge for U.S. Universities Julie T. Norris (ret.) Office of Sponsored Programs Massachusetts Institute of Technology OVERVIEW Purpose Export controls and embargoes Application
More informationDepartment of State Questions. 1. Why do I need to get the U.S. Government s approval to export and import defense articles and defense services?
Department of State Questions 1. Why do I need to get the U.S. Government s approval to export and import defense articles and defense services? Because Section 38 of the Arms Exports Control Acts (AECA)
More informationExpanding 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 informationExport 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 informationInteragency Review of Foreign National Access to Export-Controlled Technology in the United States. Executive Summary
Offices of Inspector General of the Departments of Commerce, Defense, Energy, Homeland Security, and State and the Central Intelligence Agency Report No. D-2004-062 April 16, 2004 Interagency Review of
More informationCounterterrorism and Humanitarian Engagement Project
Counterterrorism and Humanitarian Engagement Project OFAC Licensing Background Briefing March 2013 I. Introduction 1 The U.S. Department of Treasury s Office of Foreign Assets Control (OFAC) administers
More informationU.S. Department of Commerce Bureau of Industry and Security. How to Classify Your Item
U.S. Department of Commerce Bureau of Industry and Security How to Classify Your Item How is my Item Classified for Export Control Purposes? Commerce Control List ( CCL ) Export Control Classification
More informationUniversity of Virginia Export Compliance Management Program Manual
University of Virginia Export Compliance Management Program Manual Revision Date: 4/22/2013 1 ACRONYMS AECA BIS CFR DDTC EAA EAR ITAR OEC OFAC PL RPS TCP USC Arms Export Control Act Bureau of Industry
More informationwww.learnexportcompliance.com
2 3 4 5 6 EAR "Technology"--Specific information necessary for the "development", "production", or "use" of a product. The information takes the form of "technical data" or "technical assistance". "Technical
More informationTrade 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 informationAudit Module: Self-Assessment Tool
U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY & SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT & COMPLIANCE DIVISION www.bis.doc.gov EXPORT MANAGEMENT & COMPLIANCE PROGRAM Audit Module: Self-Assessment
More informationTable of Contents 738.1 INTRODUCTION (CCL) STRUCTURE
Commerce Control List Overview and the Country Chart Part 738 page 1 Table of Contents 738.1 INTRODUCTION... 1 738.2 COMMERCE CONTROL LIST (CCL) STRUCTURE... 1 738.3 COMMERCE COUNTRY CHART STRUCTURE...
More informationEXPORT COMPLIANCE PROGRAM MANUAL. University of Delaware
EXPORT COMPLIANCE PROGRAM MANUAL University of Delaware Revised 01/2013 List of Abbreviations APRRA BIS CCL CJ DDTC EAR ECCN EO URC ITAR OFAC RO PI SDN List TCP USML UD Associate Provost for Research &
More informationExport Controls Just the Basics NCURA REGION VI & VII SPRING MEETING APRIL 2012
Export Controls Just the Basics NCURA REGION VI & VII SPRING MEETING APRIL 2012 Welcome! Marci Copeland Adilia F. Koch Kay Ellis Overview Export control regulatory framework Important terms Fundamental
More informationwhite paper Mitigate Risk in Handling ediscovery Data Subject to the U.S. Export Control Laws and Regulations
white paper Mitigate Risk in Handling ediscovery Data Subject to the U.S. Export Control Laws and Regulations WWW.EPIQSYSTEMS.COM 800 314 5550 Mitigate Risk in Handling ediscovery Data Subject to the U.S.
More informationCLOUD COMPUTING, EXPORT CONTROLS AND SANCTIONS. By Richard Tauwhare, Dechert LLP i
CLOUD COMPUTING, EXPORT CONTROLS AND SANCTIONS By Richard Tauwhare, Dechert LLP i This is a summary of an article originally published in the August 2015 edition of The Journal of Internet Law and is reprinted
More informationBest 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 informationExport Control Compliance Program Guidelines April 2015
Export Control Compliance Program Guidelines April 2015 UML Export Control Guidelines rev4-16-15.docx - 1 - TABLE OF CONTENTS Introduction... 3 Institutional Policy (Management Commitment)... 4 Federal
More informationExport Control Management & Compliance Plan
Rensselaer Polytechnic Institute Export Control Management & Compliance Plan Office of the General Counsel Rensselaer Polytechnic Institute 110 8 th Street, Troy, New York 12180 October 1, 2012 (This page
More informationLouisiana State University A&M Campus Export Control Compliance Manual October 2013
Louisiana State University A&M Campus Eport Control Compliance Manual October 2013 Acknowledgements: The information in this document has been derived from sources including University of Massachusetts
More informationROCHESTER INSTITUTE OF TECHNOLOGY EXPORT COMPLIANCE PROGRAM
ROCHESTER INSTITUTE OF TECHNOLOGY EXPORT COMPLIANCE PROGRAM Message of the Provost Rochester Institute of Technology is committed to full compliance with the laws and regulations of the United States,
More informationCOMPLIANCE GUIDELINES: HOW TO DEVELOP AN EFFECTIVE EXPORT MANAGEMENT AND COMPLIANCE PROGRAM AND MANUAL
U.S. DEPARTMENT OF COMMERCE BUREAU OF INDUSTRY AND SECURITY OFFICE OF EXPORTER SERVICES EXPORT MANAGEMENT AND COMPLIANCE DIVISION COMPLIANCE GUIDELINES: HOW TO DEVELOP AN EFFECTIVE EXPORT MANAGEMENT AND
More informationAnnaLisa Nash Export Control Officer, NDSU
! Cyber Security and Export Controls: You Need to Know More Than You Already Do! AnnaLisa Nash Export Control Officer, NDSU Why Should You Care About Export Controls? so you can avoid HERE. When Should
More informationEXPORT COMPLIANCE OFFICE (ECO) MANUAL
EXPORT COMPLIANCE OFFICE (ECO) MANUAL LIST OF ABBREVIATIONS BIS CCATS CCL CJ CMU CTTEC DDTC EAR ECCN ECO EO FBE FFRDC FRE IEEPA ITAR NREC NSDD OFAC ORIC RPS SDNL SEI TCP TWEA USML Bureau of Industry and
More informationSince the events of September 11,
Reproduced by permission. 2004 Colorado Bar Association, 33 The Colorado Lawyer 117 (October 2004). All rights reserved. PROFESSIONAL CONDUCT AND LEGAL ETHICS Federal Anti-Terrorism Laws And Law Firm Clients
More informationTECHNOLOGY CONTROL PLAN TEMPLATE
Boston University TECHNOLOGY CONTROL PLAN TEMPLATE Developed and Approved by Marie Hladikova, Export Control Director Boston University, Office of Research Compliance Date: Revised March, 2015 1 1) COMMITMENT
More informationTable 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 informationExport Record Keeping Requirements. July, 21 2011
Export Record Keeping Requirements July, 21 2011 Presenter Michael J. Ford Vice President of BDP International for Regulatory Compliance and Quality Over 31 years of service with BDP working in both Import
More informationA Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW s International Activities
OFFICE OF THE VICE PRESIDENT AND GENERAL COUNSEL LEGAL ADVISORY A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW s International Activities Posting Date: April 2006 Prepared by Patton
More informationWhat You May Not Know About Sanctions (And How It Can Hurt You) by: Rajika Bhasin Counsel, Global Markets AIG
What You May Not Know About Sanctions (And How It Can Hurt You) by: Rajika Bhasin Counsel, Global Markets AIG What You May Not Know About Sanctions (And How It Can Hurt You) Introduction Companies navigating
More information2011R01020/JMM UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY INFORMATION. The defendant having waived in open court prosecution
2011R01020/JMM UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY UNITED STATES OF AMERICA Criminal No. 12- v. 18 U.S.C. 371 ULRICH DAVIS INFORMATION The defendant having waived in open court prosecution
More informationINSTRUCTIONS FOR COMPLETING THE USPTO CERTIFICATE ACTION FORM
INSTRUCTIONS FOR COMPLETING THE USPTO CERTIFICATE ACTION FORM The completed form should be sent to: Box EBC Washington D.C.20231 Block 1- Requestor Status The Certificate requester should check the appropriate
More informationexported Defense Articles Without a License
Department of State 126.1 125.7 Procedures for the export of classified technical data and other classified defense articles. (a) All applications for the export or temporary import of classified technical
More information1. Not Subject to the EAR and Defense Article. (1) Reserved. (2) Reserved
1. Not Subject to the EAR and Defense Article 734.3 (a) (NO REVISION) (b) The following are not subject to the EAR: (1) (NO REVISION) (2) (NO REVISION) (3) Information and software that: (i) Are published,
More informationCHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS
REVISED 10/19/12 CHAPTER IV: SECTION 7 COMPLIANCE WITH U.S. SANCTIONS Policies and Procedures of Society of Exploration Geophysicists with respect to Membership, Publishing Activities, and Scholarships
More informationProcessing of Deemed Export License Application. Robert Juste Electronics and Materials Division
Processing of Deemed Export License Application Robert Juste Electronics and Materials Division 1 License Application Process Submit Application Initial Analysis Conduct technical & policy review EO DAYS
More informationMedical Mission Pack Program
Medical Mission Pack Program For over 125 years, Johnson & Johnson has been committed to improving the health and well-being of mothers and children around the world. With the support of its operating
More informationLATEST ON THE DODD-FRANK ACT AND INTERNATIONAL COMPLIANCE RISKS
Missouri Bar Annual Meeting, September 12, 2014 LATEST ON THE DODD-FRANK ACT AND INTERNATIONAL COMPLIANCE RISKS Presented by: Jennafer Watson, Chief Compliance Officer Layne Christensen Company Emmanuel
More informationDevelopments in UE export controls. Jasper Helder, Baker & McKenzie Amsterdam 9 November 2012
Developments in UE export controls Jasper Helder, Baker & McKenzie Amsterdam 9 November 2012 How are EU Export Controls regulated? International EU National (EU Member State) International 2009 Baker &
More informationFundamentals 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 informationWisconsin International Trade Conference
Wisconsin International Trade Conference The Role of Trade Compliance In Corporate Strategic Decisions Related To Mergers And Acquisitions, New Product Development, And New Market Entry May 7, 2015 Wisconsin
More informationFreight 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 informationUS EXPORT CONTROLS & MARGARET M. GATTI, ESQ. LOUIS K. ROTHBERG, ESQ. FEBRUARY 23, 2012. www.morganlewis.com
US EXPORT CONTROLS & CLOUD COMPUTING MARGARET M. GATTI, ESQ. LOUIS K. ROTHBERG, ESQ. FEBRUARY 23, 2012 www.morganlewis.com WHAT IS CLOUD COMPUTING? Cloud Computing is a broad term with varied meanings
More informationIndian Webinar Series:
Indian Webinar Series: National Security and Other U.S. Government Regulatory Requirements for U.S. India Inbound or Outbound Sales, Joint Ventures, Mergers and Acquisitions Valerie Demont, Michael Hordell,
More informationDirector 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 informationInsights and Commentary from Dentons
dentons.com Insights and Commentary from Dentons The combination of Dentons US and McKenna Long & Aldridge offers our clients access to 1,100 lawyers and professionals in 21 US locations. Clients inside
More informationTHE EVERGREEN STATE COLLEGE
The Evergreen State College Procurement Card Guide JP Morgan Chase VISA THE EVERGREEN STATE COLLEGE PROCUREMENT CARD HANDBOOK For Cardholders & Authorized Users Card Custodians Approving Officials Rev
More informationRSA. Frequently Asked Questions. RSA Data Security, Inc. About Cryptography Export Laws. Answers to THE KEYS TO PRIVACY AND AUTHENTICATION
RSA Data Security, Inc. Answers to Frequently Asked Questions About Cryptography Export Laws RSA DATA SECURITY, INC. THE KEYS TO PRIVACY AND AUTHENTICATION Copyright Notice Copyright 1996 by RSA Data Security,
More informationExport 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 informationAction 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 informationEvaluation, Development and Demonstration Software License Agreement
Evaluation, Development and Demonstration Software License Agreement IMPORTANT PLEASE CAREFULLY READ THE FOLLOWING LICENSE AGREEMENT, WHICH IS LEGALLY BINDING. DO NOT DOWNLOAD OR INSTALL THE LICENSED MATERIALS
More information