EAR/OFAC Export Controls e-Seminar Modules (for Non-U.S. Companies) | ECTI

Introduction to U.S. Commercial Export Controls

Key Control Concepts
Comparison to International Controls
Export Administration Regulations
Bureau of Industry and Security

Items and Persons Subject to U.S. Jurisdiction

Controls on “U.S. Persons”
Controls on U.S. Origin Hardware, Software and Technical Data
Controls on Non-U.S. Manufactured Items Containing U.S. Origin Content
U.S. De Minimis Content Calculation

Export Classification and Export Determination

ECCN Classification
“No License Required” Determination
License Exception Determination
Red Flag, Denied Party and Proliferation Screening
New China Military Catch All Rule
License Requirements

U.S. Embargo and EAR Special Country Controls

Office of Foreign Assets Controls (OFAC)
OFAC Comprehensive Embargoed Countries: Iran, Sudan and Cuba
OFAC Licensing and Approval Policy
EAR Special Country Controls: Syria, North Korea
Control Status of Libya, Iraq and Palestine
Specially Designated Nationals

EAR Antiboycott Regulations

Introduction
Relationship to Arab League Boycott on Israel and other Boycotts
Applicability to Transactions Outside the US
Prohibitions and Exceptions
Reporting Requirements

Export Control Reform

List Shifts: Military Items Changing from ITAR to EAR Jurisdiction
New 600-Series ECCNs
New “Specially Designed” Definition (EAR & ITAR)
Handling Existing Licenses & Approvals
Transitioning to New Rules

Export Enforcement

How U.S. Rules are Enforced Outside the U.S.
Corporate and Personal Fines and Penalties
Enforcement Case Studies
Preventing Violations

Compliance Programs

Considerations for Developing a Corporate Export Compliance Program
Types of Procedural Approaches
U.S. Government Compliance Program Recommendations

Technical Data Considerations

Controls on Physical and Intangible Data
Deemed Exports and Reexports
Third Country National Considerations
Emailed Data, Server Access and Downloads