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 companys 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 "Complying with US Export Controls"

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(starting on pdf page 1 through page 69.)

Step 2: Use the supplements (Commerce Country Chart,

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Alphabetical Commerce Control List

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and the Electronic Code of Federal Regulations (Links to an external site.)-Supplement No. 1 to Part 774The Commerce Control List (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 Directions

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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) You email blueprints to South Africa for a chemical processing facility you plan to build there. a) Is this transaction subject to the EAR? b) Would it make a difference if the email was sent to your own staff in South Africa as to whether the transaction was 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: Inflatable Boat Specifications:

Dimensions: Length 8 feet, Beam 4 feet. Weight (Empty): 401bs. Capacity: 4 people Price $ 600 Multiple air compartments for safety. A) Identify the ECCN and the reason(s) for control: _________________________

Identify the ECCN and the reason(s) for control:

ECCN: _____________ Reason(s) for control_______________________________

Next determine the export licensing requirements for the following destinations:

Destination	CCL based License Requirement (Y or N?)	List Based License Exceptions
Germany
Sudan
Libya
Syria

4. Shotguns with 20" barrel length.

   ECCN: Reason(s) for control: ________________

5. Field programmable logic devices having a maximum number of single-ended digital input/outputs greater than 700.

ECCN: Reasons for Control: _________________________________________

6. 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: _____________________

7. 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

8) The researchers need a cryo-cooler for their detectors. The cryo-cooler is controlled under 6A002.d.2.b. Is there an export license required for this component which costs $2,500, to ship to Germany?

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