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Export Compliance Programs: Policies and Procedures and Technology Control Plans

On December 30th, the new State and Commerce Departments rules regarding military electronics went into effect, transitioning many parts out of the jurisdiction of USML Category XI. As more and more previous ITAR jurisdiction products are controlled by the EAR, it is important to update out of date Export Policies and Procedures and Technology Control Plans to reflect the changes.

Export Policies and Procedures are an export compliance program that primarily controls sales/shipment of product but also have controls set for technical data, detail proper export documentation & record keeping, and detail a company’s audit and training plan. The Technology Control Plan is a guide to restrict controlled information and product from foreign visitors and employees. Together, a company’s Policies and Procedures and Technology Control Plan are a necessary export compliance program to ensure compliance with changing U.S. export laws in the wake of Export Control Reform.

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