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Export Reminders for the Start of 2018

As 2018 begins, there are a number of things that exporters should remember to do on a yearly basis to make sure they are in compliance with U.S. export laws and regulations.

 

Training: All export- decision making employees should receive training on a yearly basis.  Additionally, any new export involved employees should be trained within 90 days of hire and should be supervised during their involvement with export activities prior to completion of this training.

 

Audit: An audit or review of your company’s export sales and transactions should be carried out on an annual basis to ensure compliance to U.S. Export Laws and Regulations and to your company’s Export Policies & Procedures. This review or audit can be completed by the company official in charge of export transactions (the Export Control Officer) or by an external consultant. An audit guide should be drafted and followed to ensure all aspects of export compliance are reviewed.

 

Registration: Manufactures and exporters of ITAR jurisdiction items and technical data are required to register with the State Department.  An expiration notice will be received by email from DDTC, but you should track your company’s registration expiration date in case the email is overlooked.

 

Licensing: Exporters should review expiring licenses and apply for needed renewal/replacement licenses several months prior to the expiration to prevent a gap in licensing. The review of licenses and agreements should also include review of any licensing authority required to be replaced or amended due to Export Control Reform.

 

Policies & Procedures: Companies should review their Export Policies and Procedures and Technology Control Plans annually and make any necessary updates based on changes in regulations and/or internal company procedures.  It is also a good way to refresh export involved employees (along with the audit/review) on the requirements included in the Policies and Procedures and confirm that the written procedures are being followed and are understood.

 

Vendor/Supplier Certifications: Prior to your company’s transfer of controlled technical data, vendors and suppliers should be required to confirm their compliance with ITAR/EAR regulations through a supplier certification letter, which should be renewed on an annual basis.  A system should be implemented to track the dates the certifications are signed to ensure new certifications are received annually.

Annual Report of Sales: Annual Report of Sales should be filed for all valid DAs/MLAs by January 31, 2018.

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