Export Control Exercise

 Export Control Exercise Directions Export Compliance has become very critical in international trade today. Unfortunately, many companies are finding this out the hard way by paying large fines in penalties. (i.e., Weatherford) Naturally, there is a growing demand for jobs in export compliance, which pays quite well. New rounds of changes in export controls happened in October, 2013 and more reforms are on the way. Export Compliance is technical in nature. For example, an Export Compliance Manager has to work closely with the Engineering Department to understand the complexities of the company’s products as to whether licenses are required. These following exercises will give you an overview of what export compliance entails and how to determine whether a license is needed, or not. Step 1: Read the Powerpoint Supplement (BIS-Complying with US Export ControlsPreview the document) starting on pdf page 11 through page 80. Step 2: Use the supplements (Commerce Country Chart,Preview the document Alphabetical Commerce Control ListPreview the document and the Electronic Code of Federal Regulations (Links to an external site.)Links to an external site.-Supplement No. 1 to Part 774—The Commerce Control List (Links to an external site.)Links to an external site. ) to help you find your answers. Due to the technical nature of Export Controls, follow the instructions carefully. Step 3: Answer the questions below from Powerpoint Units I, II,& III. Examples from each of the Units are given for you to follow first before you answer the assignment questions (See attached Export Controls Assignment DirectionsPreview the document file ). Please note that most questions have more than one part to them. Export Control Exercises; Powerpoint Units 1 – 3 (7 questions total) Answer the following Unit I (Overview of the Export Administration Regulations) questions: 1) A shipment of a fifty gallon drum of “sodium cyanide” that is used in the mining process involves items that are manufactured in Brazil using U.S. origin controlled parts valued at less than 25% of the value of the end product. This end product will be shipped from Brazil to Frankfurt, Germany. Is this transaction subject to the EAR? Now answer the following Unit 2 (Classification of Items on the Commerce Control List) questions: 2) In which part of the EAR would you find the ECCN entries and their technical parameters? 3) Product: Nuclear Radiation Shielding Window Specifications: Made of high density lead glass. Cold area = 0.10 m2 Density = 3.3g / crrr’ Thickness = 100 mm Designed for general laboratory and medical research applications. Not specially designed for nuclear reactors or reprocessing facilities. Identify the ECCN and the reason(s) for control. Next determine the export licensing requirements for the following destinations: ECCN: _____________ Reason(s) for control_______________________________ Destination CCL based License Requirement (Y or N?) List Based License Exceptions Germany Brazil Libya Syria Devices primarily useful for the surreptitious interception of wire, oral, or electronic communications, other than those controlled under 5A001.f.1; and “parts,” “components” and “accessories” thereof. ECCN: Reasons for Control: _________________________________________ 5. Filament winding machines of which the motions for positioning, wrapping and winding fibers are coordinated and programmed in three or more “primary servo positioning” axes, specially designed for the manufacture of “composite” structures or laminates from “fibrous or filamentary materials”. It is capable of winding cylindrical rotors having a diameter between 100 to 300 mm and lengths greater than 700 mm. ECCN: _____________________ Reasons for Control: _____________________ 6. Integrated circuits radiation hardened to withstand a total dose of 5x 1 03 Gy (Si) or higher and usable in missiles. ECCN: ___________ Reason(s) for control: ________________________ UNIT III: Determining Licensing Requirements Based on the ECCN and Destination 7) You export optical sighting devices controlled under ECCN OA987 to Argentina. a) Is there an export license required? b) There is another shipment of these same optical sighting devices to Japan. Would the shipment to Japan require an export license?