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Roll Out of New MPC&A ICL

Roll Out of New MPC&A ICL. Dr. Ron Rudolph DOE/NNSA NA-25. Since Last We Met. Improved Internal Control Program (ICP) released New commodity disposition procedures released New ICL issued. Improved MPC&A ICP. Significant expansion requested by Commerce during 2004 HQ Compliance Review

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Roll Out of New MPC&A ICL

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  1. Roll Out of New MPC&A ICL Dr. Ron Rudolph DOE/NNSA NA-25

  2. Since Last We Met • Improved Internal Control Program (ICP) released • New commodity disposition procedures released • New ICL issued

  3. Improved MPC&A ICP • Significant expansion requested by Commerce during 2004 HQ Compliance Review • Include all who are involved in ICL process • Clearly identify responsibilities and requirements • Describe review and approval procedures

  4. Improved MPC&A ICP (cont.) • Drafts of initial revisions reviewed by Commerce Compliance Office • Draft reviewed by Lab MPC&A Export Managers and Headquarters Project Managers • Released September 2005 • Implemented as a real-time document on the MPC&A Website as part of new ICL application April 2006

  5. Commodity Disposition Procedures • ICL and IVL conditions require Commerce approval of sale, transfer or re-export commodities • Procedures address transfer, cannibalize, destroy/dispose or abandon • Russian law on gratuitous technical assistance (taxes) impacts the decisions to transfer

  6. Commodity Disposition Procedures (cont.) • Draft procedures sent to LMEMs last spring • Input from property management sections • Flow chart – share with anyone • Written procedures – limit to U.S. team members to avoid political issues • Not assume to know or understand tax laws • Not appear to direct foreign activities

  7. Chronology of New ICL • ICL S000005 to expire February 2006 • Polled LMEMs for changes and additions • Discussions with Commerce summer 2005 • Applied for new license September 14, 2005 • 30-day extension for interagency review • Verbal approval March 30, 2006 • Suspended use of S000005 March 30, 2006 • Implemented S000030 on Website April 10, 2006

  8. Structure of New ICL • Updated Commodity List • Reclassified non-proliferation (999) items • Add explosives detectors (2A983) • Scrubbed Consignee List • Remove abandoned sites • Add two new sites • Correct/update names and addresses

  9. Lessons Learned • Coordinate with • LMEMs and project managers • Commerce before start • Communicate • Expect delays and problems • Commerce computer limitations • Interagency questions

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