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MEC EXPORT COMPLIANCE AWARENE$$

MEC EXPORT COMPLIANCE AWARENE$$. Presented by : Paul Divecchio –DiVecchio & Associate Phone: (617) 513-3230, Fax: (508) 393-3645 Email: pauldivec@earthlink.net. Export Compliance Decisions. IT OUT, NOT :. WHEN IN. WHEN IN. IT OUT.

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MEC EXPORT COMPLIANCE AWARENE$$

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  1. MEC EXPORT COMPLIANCE AWARENE$$ Presented by : Paul Divecchio –DiVecchio & Associate Phone: (617) 513-3230, Fax: (508) 393-3645 Email: pauldivec@earthlink.net

  2. Export Compliance Decisions IT OUT, NOT: WHEN IN WHEN IN IT OUT 1. USE COMMON SENSE!! Everybody Has it?? 2. Document Decisions Demonstrate your D2 “Due Diligence” 3. Abide by the Exporters Cardinal Rule

  3. What You Know! Stated & Implied

  4. Company Objective • Don’t be an Ostrich ! • ENHANCE EXPORT OPPORTUNITIES • RISK AVOIDANCE

  5. CURRENT CLIMATE • Mandatory AES Compromised (DHS vs. Census) • Patriot Act Penalty Increase - $10K to $50K • PRC – “Catch All”-conventional military • Enforcement Oversight - AGRESSIVE • Industry Compliance Initiative – A MUST

  6. What can happen if it goes wrong? • Fines • Negative Publicity • Denial export Privileges • Disruption of Business • Jail Time

  7. Methods of Enforcement • Industry Sources - Informants • Intelligence Sources • Outreaches • Safeguards Verification Program • Visa Application Review Program • Export Document Review (Targeting) ( SED/AES, Airway Bills, Bills of Lading) • Public Sources - Newspapers, Trade Publications, Internet

  8. KEY EXPORT COMPLIANCE RISKS • WRONG JURISDICTION (Boeing –L3) • CLASSIFICATION (NONE/WRONG) • GLOBAL DENIED PARTY REVIEWS • SLOPPY PAPERWORK • EMBARGOES – DIVERSIONS • ANTIBOYCOTT COMPLIANCE • TECHNICAL DATA TRANSFER • EMPLOYEES • OUTSOURCE • CUSTOMER’S DATA • SPONSOR LETTERS FOR VISAS

  9. Some helpful websites • www.bis.doc.gov - Bureau of Industry & Security (BIS), U.S. Dept of Commerce -BIS EAR, press releases • BIS web site “RESOURCE LINKS” takes you to other federal agency web sites • www.census.gov/foreign-trade/schedule/b/index - U.S. Census Bureau - Schedule B Nos. • www.treas.gov/offices/eotffc/ofac – Office of Foreign Assets Control (OFAC)- summary sheets on embargoed (and other) countries • www.cbp.gov/xp/cgov/export/aes - U.S. Customs and Border Protection - Automated Export System (AES)

  10. EFFECTIVE COMPLIANCE PROGRAMS EXECUTIVE COMMITMENT • Corporate Governance – establish a “code of conduct” • Compliance Focal Point • Location/Authority/Skill Sets/Budget/Recognition • Compliance Team • Engagement – High Morale • Global Compliance • All Divisions • Subs/Branches/JV • Unaffiliated • Compliance Assessments (not audits) • Include acquisitions • Education – Corporate Awareness • U.S. and Overseas Affiliates

  11. HOW TO ACHIEVE ! KEY COMPANY ISSUES • RESOURCE COMMITMENT • Classification of products/technology • Technology Transfer Monitoring • Company Export Compliance Manual (formal) • Company Personnel Awareness (training/education) • Integration of Compliance with acquisitions • Subsidiary Compliance • Pro-act with governing licensing agencies • Automation of the Compliance Program

  12. Company Compliance“Today” • Corporate Education (company awareness-global) • Corporate Training (operational personnel) • Roll out Formal Compliance Program • Form Compliance Committee • Automate Compliance Checks Wherever Possible • < Maintain a Robust Program >

  13. EVERYONE'S ACCOUNTABLE

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