Export Compliance Implementation Plan

Immediate Actions

  1. Assure that all exports are accurately classified and the export control documents contain the proper destination control statement, this includes Bill of Lading, Airway Bill, Commercial Invoice, Packing Slip.

All items (commodities, technology, and software) shall be classified in order to determine jurisdiction (ITAR OR EAR), and with specific ECCN, EAR99 or USML Category. Every effort shall be made to ascertain the export classification status of an item during the contract negotiation and acceptance phase. In those instances where the client states, that the item is not controlled by U.S. export laws and regulations, or that they do not know if the item is controlled, the Export Compliance Manager shall review the item’s technical characteristics and determine whether or not the item is subject to the controls of the U.S. government. Regardless, of the export determination results, all such reviews shall be documented and retained for five years.

2. All Non-U.S. Person Visitors will be screened. Results of screening shall be maintained for five years.

http://www.bis.doc.gov/complianceandenforcement/liststocheck.htm

Non-U.S. persons will not be given visual and/or physical access to export-controlled products or information without an approved license or other authorization.

All visitors are required to show legal proof of identity (passport or drivers license) as a condition of access. Each visitor is also required to complete a log entry indicating their name, company affiliation, country of citizenship, date, time of arrival and Company issued badge number. All Non-U.S. visitors are required to read and sign the “Memorandum of Understanding” certifying that they have read and understand the rules, which they shall follow while on Company premises.  

3. DDTC Registration shall be completed.

4. Empowered Official shall read and become familiar with the ITAR, EAR and FTR.

ITAR:  http://www.ecfr.gov/cgi-bin/text-idx?SID=9083862fbead7aa13ccf88f0e4e7cc60&mc=true&tpl=/ecfrbrowse/Title22/22CIsubchapM.tpl

EAR: http://www.ecfr.gov/cgi-bin/text-idx?SID=9083862fbead7aa13ccf88f0e4e7cc60&mc=true&tpl=/ecfrbrowse/Title15/15CVIIsubchapC.tpl

FTR: http://www.ecfr.gov/cgi-bin/text-idx?SID=9083862fbead7aa13ccf88f0e4e7cc60&mc=true&tpl=/ecfrbrowse/Title15/15cfr30_main_02.tpl

5. President shall issue in writing the appointment of the Empowered Official.

6. All employees shall read and acknowledge the TCP  and policy.

7. All contractors who have access to facilities will provide positive evidence of U.S. Persons.

8. All contracting agencies and organizations shall be screened, results of screening shall be maintained.

9. Access to company servers and data that contain controlled data shall be limited to U.S. Persons.

10. All suppliers who perform repair, testing, or manufacturing of Defense Articles shall be DDTC Registered.