Export Compliance Policy: Controlled Export Methodology
The following methodologies are intended to briefly address policies and procedures related to controlled items and technical data:
Identification, Receipt and Tracking of ITAR Controlled Items/Technical Data
Employees working directly with sales, contracts, shipping, and compliance are expected to maintain a working knowledge of the AECA and ITAR provisions.
Company employees will be notified of applicable changes in U.S. export control regulations via the Compliance Department. Notices will be distributed in regular training sessions or via e-mail.
Questions regarding the interpretation of the AECA or ITAR will be addressed by the Compliance Department or a member of senior management. Employees are prohibited from interpreting questionable portions of the AECA or ITAR without assistance.
Export sensitive U.S. origin technical data produced by your company must be approved by the Compliance Department or a member of senior management prior to export. Exports of technical data must be marked as export sensitive and must display an appropriate destination control statement.
Restricted/Prohibited Exports and Transfers
New customers, carriers, and export countries will be subject to an initial investigation by the Compliance Department to ensure exports to that entity or country are not restricted. Existing customers will be updated as needed.
Screening procedures will include:
Comparison of the party in question to denied parties lists,
A search of DoC, DoD, and CBP regulations regarding denied countries
A search of the Federal Register to determine federal restrictions against a carrier.
In the event that evidence of diversion or unauthorized use of U.S. origin products is discovered, the Compliance Department in conjunction with senior management will make every effort to determine and document that a diversion or misuse took place. The empowered official will make a final determination to report the infraction to the DoS, DoC, CBP, or other government agency.
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Aug 21, 2008 14:54:15
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