An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. Freight forwarders can provide excellent expertise and guidance on logistics and may have some knowledge of your export business but the exporter is principally responsible for that task. Faa lobs and staff offices are responsible for ensuring compliance with all applicable export control requirements bef ore engaging in an international transaction. As americas biggest manufacturing exporter, the company supports airlines and u. The um export control program covers all um campuses, including regional campuses such as um dearborn and um flint, and the manual is intended to be used by all um campuses to assist in identifying and managing export control issues and to ensure compliance with export control laws. The purpose of this letter is to highlight the dept. Identify an office at the university in charge of export control training and compliance 1. Interdepartmental export control coordinating body an interdepartmental export control coordinating body will be established to secure the implementation of state policy in the sphere of export control, including compliance with international export control standards, and coordinate the activities of federal agencies of. Such compliance shall include, but not be limited to, laws regarding minimum wages. Introduction to export control compliance selfguided. Hr will provide the secure data storage and access control. Export control compliance verification form fill online, printable.
Policy summary it is the policy of the university to comply with u. The eaa is the basic authority for bis to to issue regulations, and to. American conference institutethe canadian institutes 3rd. A wednesday, november 01, 2017 page 1 of 8 f82201, rev. The checklist helps orc staff determine whether export controls apply to proposed projects, if any exemptions apply, or if a technology control plan tcp, an export license. Sue gainor is vice president of global trade controls for the boeing company. Bae systems is committed to maintaining an effective system of export control compliance that is designed to avoid violations, detect them promptly if they occur, and provide timely responses, including prompt investigations and appropriate remedial actions. International trade compliance poses a significant challenge for global businesses, given the constantly changing regulatory landscape. Exporters obligation to determine the applicable export. The task force and hughes believe that the identification of these best practices may prove useful for other companies in their efforts to comply with u.
Individual cases should be addressed with mit export control early and often. The boeing company general provisions doing business. Faculty, and in particular researchers, are responsible to familiarize themselves with the universitys export control policy and the circumstances under which export control laws and regulations might be triggered. Faqs export controls compliance office of research. The boeing ethics line 18889707171 is staffed during u. As part of this enforcement trend, the various government agencies with responsibility for enforcing export control regulations have increasingly turned their attention to compliance in the higher education setting. Technical data, software, and defense services directly related to such parts or components must be controlled under the itar as well. Employment decisions are made without regard to race, color, religion, national origin, gender, sexual orientation, gender identity, age, physical or mental disability, genetic factors, militaryveteran status or other characteristics protected by law. Stefan reisinger senior counsel norton rose fulbright washington, dc the.
We are enhancing the form to obtaindetermine export control classification information for items and data. To use boeing furnished datasets as authority for design, manufacture or inspection of product andor tooling, a supplier must comply with this document. The witness must check with the export compliance officer if using a document other than an unexpired foreign passport. Strengthened compliance system with uptodate and efficient export classification and restricted party screening processes usage audit reporting features to prove compliance raises the level of compliance at your university as well as enhances your ability to make your export compliance workflow an efficient and sophisticated process.
Export compliance will be the group responsible for monitoring and making licensing determinations. Export controls international trade administration. The boeing company international provisions sp3 d0 6000 6007 new nov 2001 2 controlled items requiring such authorization, which are necessary for seller to perform this contract. Such controlled items are authorized for export only to sellers country for use by seller and. Due to export control reform, 36 countries are now eligible to receive items and technologies exported from the u. However, in recent years, attention to export control compliance. Background in august 2009, president obama directed the agencies involved in the u. States export control and asset control laws, regulations, and orders, as they. The advanced tools of the editor will lead you through the editable pdf template. International business opportunities burn bright for our. Us boeing badge wbemsid twic transportation workers identification card unexpired foreign passport with i94 if available other approved documentation specify document. Seller shall establish and maintain a quality control system acceptable to. Why is export compliance collecting this information instead of hr. Data protection compliance airbus is required to handle personal data in accordance with applicable data privacy laws at national, european and international level.
If yes identify type import export if applicable list regulations, requirements, export classification control number, andor hyperlinks. Export control reform and the export administration regulations. Now boeing will have to appoint an independent external officer to oversee companywide export control compliance for two years, as well as a senior manager internally. The office of research administration ora together with the office of research compliance orc launched an export compliance checklist in pars proposal approval routing system in november 2016.
The export control profile is predicated upon the notion that any u. These include management commitment, compliance organization, training and education, export compliance instruction manuals, and foreign national issues. University of georgia enhances export control compliance uga is taking deliberate steps to enhance its export control compliance program, with the goal of facilitating compliance by the research community. Use this comprehensive checklist to conduct annual compliance audits and detect itar non compliance based on export clearance requirements, itarcontrolled technical data, use of itar exemptions, and more. Master uncontrolled when printed export controls compliance policy f82201 rev. Overview of export laws and regulations the united states export laws and regulations operate to restrict the use of and access to controlled information, goods, and technology for reasons of national security or protection of trade. Apply to compliance officer, custodian, export manager and more. This is especially challenging now because of export control reform. Government program known as export control reform ecr. Make sure youre in compliance with these regulations. Articulate and publish an export control compliance policy 2. Vanderbilt export compliance manual page 5 of 40 last revision march 26, 2018 5 purpose the vanderbilt university export compliance manual manual is intended is to provide guidance on u. Boeing supplier belatedly discovered that one of the millions of parts and materials on a commercial.
Hr and export compliance are working in partnership on this effort. Boeings expanding international business depends on strict compliance with export regulations. The boeing company international provisions sp3 rev. Australian best practice guide for the management of controlled. The boeing company general provisions gp referenced in. Export regulators have placed the responsibility on universities to understand and comply with export controls. All bca suppliers partners, supplier compliance focals, etc category. It is not intended to be your sole resource for export control expertise export control compliance is often complicated and requires the judgment of the export control officer eco. The wording need only consist of the english language name of the country of origin such as france, china, or japan, unless there is also wording on the container, unit, etc. Information required by ge to apply for a department of state license, or a department of commerce license.
The way to complete the online export control compliance verification form on the internet. Boeing trade control compliance boeing maintains policies, procedures, and systems that advocate the highest level of compliance with u. Our team of domestic and international trade specialists, located at our export assistance centers in the united states and at u. The united states imposes export controls to protect national security interests and promote foreign policy objectives. To help you comply with the new rules, boeing is changing its product description form pdf. Digital product definitionmodel based definition checklist d651991 revision j revised october 12, 2010 notes this assessor task guide for the digital product definitionmodel based definition checklist is intended to provide guidance and understanding of the questions of the check list to the supplier that is undergoing a dpd assessment.
In evaluating itar issues companies should also consider issues raised under the export administration regulationssee section 37below. Our export compliance directive defines our policies, processes and organisation to ensure compliance with all relevant export control laws and regulations. Boeing is the worlds largest aerospace company and leading manufacturer of commercial jetliners, defense, space and security systems, and service provider of aftermarket support. She is responsible for export and import activities throughout the boeing enterprise, including strategy development in response to changing export import regulatory policies, trade control infrastructure, regulatory tracking, operational activities and related compliance requirements.
Please be advised that any company information posted to this webpage is for informational purposes only. Bis has not validated and is not responsible for the accuracy of the. Department of commerce export administration act reference g and export. Enter your official identification and contact details. Export control compliance program and manual issued. The kingdom of the netherlands general customs act and the strategic services act nl ec and associated nl national law and eu law covering export control and trade control legislation for dualuse and military items. Export control laws and regulations, to identify key export compliance issues related to research.
The ficci export control compliance manual 2018 is an attempt to combine best practices in internal compliance policies and procedures to safeguard organisations from exporting unauthorized items and consequently damaging the reputation of their firms and of the country, in addition to facing export penalties. Prudence a necessity on export control issuesthe boeing. Airbus has made on compliance and responsible business practices over the past several years whilst there is still work to be done, i count on all of you to continue supporting this journey by embodying the principles set forth in this code of conduct in every aspect of your daytoday work in addition to reaffirming our values, this. This form was previously used to obtain information needed to determine the schedule b and hts information for export import purposes. This form was previously used to obtain information needed to determine the schedule b and hts information for exportimport purposes. The deloitte global export controls and sanctions practice works with clients across the globe to assess, design, implement and continuously improve international trade compliance programmes. Export compliance policy and management commitment c. Movement of controlled goods in any manner, whether export, transhipment, reexport, transit, brokering or intangible technology transfer, are all subject to regulation. The eaa is the statute that authorizes the export control and antiboycott compliance activities of the department of commerce doc. Determine who needs export training, what level of training is. Central time, monday through friday and is available to boeing employees, suppliers, contractors or other business partners inside and outside of the company.
Boeingdesignated empowered officials, under the terms and conditions of code of federal regulations 22 cfr 120. The purpose of the form is to assist in verifying your export control status. The marking must be conspicuous, legible, and permanent. Export control compliance is not a task that should be outsourced to your freight forwarder. Boeing maintains policies, procedures, and systems that advocate the highest level of compliance with u. State department makes it easier to determine whether aircraft and aircraft engine. Boeing shall document supplier compliance as approved in the boeing sq supplier data system. In april 2010, former secretary of defense gates described how national security required. Respondents export compliance office that, based on a cj determination, the qrs11 was a defense article controlled under the itar. The itar defines a foreign person as any person who is not a u.
Export compliance the rules and exceptions that apply to. Ocrs global trade controls gtc helps provide a standard policy and workflow for comprehensive license screening for all movements of controlled goods and technology. The international export control regime focusing on the proliferation of nuclear. International trade compliance ge is committed to efficiently meeting customer and regulator requirements in order to minimize risks, support growth and yield a culture of global compliance. Federal regulations restricting the export of goods and technology out of the country have been around since the 1940s. Boeing also provides employees and other stakeholders detailed procedures to ensure compliance with the u. Export control compliance program guidelines january 2019. Export control policy policy summaries oversight and. Export compliance training institute comprehensive training. Boeing designated empowered officials, under the terms and conditions of code of federal regulations 22 cfr 120. Get the export control compliance verification form. Export control compliance manual northeastern university. Overview of export laws and regulations office of research.
Stanfords export control officer eco, steve eisner, formed the university export controls working group ecwg in august of 2017 with the goal to to provide a forum where steve can provide educational outreach to ecwg school and unit representatives on export control policies, procedures, and practices. Xacml for export control and intellectual property protection. Boeing maintains policies, procedures, and systems that. We also offer an expansive library of trade compliance webinars which explore more narrowly focused areas of international trade. At boeing distribution services inc discretion, we reserve the right to invoke source inspection. Export control unit department contact information export control unit, rutgers university. Export control compliance verification f1103347 0617 instructions the purpose of this form is to assist in verifying your export control status. Information security manual published by the defence signals directorate. Nonmilitary products may be classified according to the u. Foreign corrupt practices act and other global anticorruption laws and regulations. Determine who needs export training, what level of.
The boeing companys business is conducted by its employees, managers and corporate officers led by the chief executive officer, with oversight from the board of directors. Federal export control laws restrict the export of goods, technology, related technical data and certain services in the interest of protecting the national security and domestic economy. Commercial service aerospace and defense global team dedicated to enhancing the global competitiveness of the u. Export control classification numbers items characterized as dualuse or commercial and not found on the usml may be identified on the commerce control list ccl all items subject to the ear fall into one of 10 categories on the ccl within each category, items are classified by export control classification numbers eccns.
Julia reed australian aerospace formerly of boeing. Arms regulations itar or export administration regulations ear and. It is nasa policy to ensure that exports and transfers of commodities, technical data, or software to foreign persons are carried out in accordance with united states export control laws and regulations, and administration and nasa policy. Export control compliance verification form fill out and. State department makes it easier to determine whether.
Export control laws restrict certain types of information, technologies and commodities that can be transmitted overseas to entities and individuals, including u. Export control compliance verification form fill out and sign. Instructions the purpose of this form is to assist in verifying your export control status. Government license to export or re export imposes a licensing obligation for the end item to authorize the export of the itarcontrolled component.1196 32 155 663 1237 737 516 371 1181 1393 915 699 239 1563 1531 817 1397 893 361 157 1007 115 1304 646 1570 1449 1188 96 824 843 851 437 416 1224 569 996 910 269 364 940 111 1467 40