Does the Company Have a Potential Product for Export Administrators?
3M Attenti Ltd., an Israeli company, agreed to pay $230,000 to settle charges of 21 violations of the Export Administration Regulations. This case arose as a result of 3M Attenti’s voluntary disclosure about its illegal shipment of people-monitoring equipment, software and technology to China and violation of the deemed export rule. The violation of the deemed export rule involved the transfer of technology controlled in ECCN 3E980 to an employee who is an Israeli national. Since the technology requires an export license for Israel, the company should have gotten a license before it released the technology to an Israeli national in the United States.
The violations included 20 charges of illegal exports of people-monitoring hardware, software, and technology to China. People-monitoring technology includes things like the electronic monitoring bracelets you have to wear if you are a famous actress and get caught drinking and driving too often. The US Government controls this technology because of concerns of how it may be used by law enforcement in certain countries—it’s not that the US Government does not want the Chinese Government to keep tabs on its drunk actresses, but the USG certainly does not want these things to be used to monitor the movement of dissidents or to violate human rights.
Besides being used for law enforcement purposes, these devices can be used in elder to for wander management and fall detection.
I once got in trouble for suggesting using a Taser on a sales and marketing person who intentionally committed a violation that caused his company to get penalized. If that bothered you, I suggest you skip ahead to the next article.
For everybody other than that one guy, do you see the obvious export compliance program applications for these products? Just think if you take your existing visitor program and enhance it with one of these bracelets for “wander management.” You authorize a visitor into your facility, you program his bracelet for the areas he may access, and you have him wear the bracelet. If he ends up wandering into your military R&D area, your wander management system could alert you immediately or maybe sound a loud alarm, maybe one of those old fashioned air raid warning alarms. Or, if you are looking for best practices wander management, when the visitor goes into an authorized area, the bracelet delivers a slightly less than lethal electric shock (see past articles on Tasing). To be humane, you could have settings so that if he gets within 10 feet of an unauthorized area, he gets a slightly weaker electric shock.
And think about how this can help with that pesky engineer or sales guy who just doesn’t want to do the right thing when it comes to compliance. 2012 could be beginning of a new era.
(Don’t tell HR.)