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October 11, 2011 Compliance with AES A Practical approach

October 11, 2011 Compliance with AES A Practical approach. About Teradyne. Founded: 1960 Global headquarters: 600 Riverpark Drive, North Reading, MA President and CEO: Michael A. Bradley Employees: 3,000 worldwide Stock ticker: NYSE:TER 2010 Sales: $1,566M

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October 11, 2011 Compliance with AES A Practical approach

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  1. October 11, 2011Compliance with AESA Practical approach

  2. About Teradyne • Founded: 1960 • Global headquarters: 600 Riverpark Drive, North Reading, MA • President and CEO: Michael A. Bradley • Employees: 3,000 worldwide • Stock ticker: NYSE:TER • 2010 Sales: $1,566M • About: Teradyne is the leading supplier of Automatic Test Equipment used to test complex electronics used in the consumer electronics, automotive, computing, telecommunications, and aerospace and defense industries.

  3. Our products

  4. Summary Management of Export filings is more important today than in the past. Information is electronic and violations can be easily (auto) identified by enforcement. US Customs is enforcing EEI compliance Penalties are being issued for minor clerical errors. Exporters must review their export compliance procedures to ensure a high level of compliance. Current controls may not be adequate. Manage forwarders closely Maintain proper procedural checks and controls Recordkeeping Audits

  5. Checking exports for accuracy Teradyne shippers must complete a pre and post shipment checklist for every shipment

  6. Checking exports Was the “Port of export” filed correctly? Was the correct “Date of export” filed correctly? Port codes can be confusing. Example: Would you be concerned if a forwarder provided you with a port code of 2704 for shipment from LAX? 2704-LOS ANGELES, CA 2709-LONG BEACH, CA 2720-LOS ANGELES INT ARPT, CA 2770-DHL, LOS ANGELES, CA 2775-TNT EXPRESS, LAX, CA 2791-DHL-HUB LOS ANGELES, CA “if the export information is wrong, then penalties are possible. Given the number of shipments that FedEx does for exporters, the number of penalties could mount very rapidly.” Robert C. Rawls Outbound Branch Chief U.S. Customs and Border Protection

  7. Audit your exports Do you request a copy of your ETRAC export information via FOIA for audit purposes? Once per year is free! You may be surprised when you review the data.

  8. Forwarder management • Do you manager your Power of Attorney? • Does shipping provide the forwarder a signed SLI? • Do you have a SOP in place with your forwarder? • Has the forwarder agreed to indemnify you if they cause a violation and you are penalized? • Do you provide a signed SLI for routed shipments? The forwarder may be listing you as the exporter. • Do you require communication between exporter and forwarder to be in writing?

  9. Do you permit Routed shipments? • Teradyne does not recommend the use of routed shipments. • Standard Incoterms are FCA or DAP • Teradyne has full control over EEI submission, can access and edit via AES • Customer friendly policy, Teradyne is providing a service to our customer • Reduces export delays, customer / forwarder are not experts at exporting Teradyne products, we are. BIS Best Practice #4 – “Companies should avoid routed export transactions when exporting and facilitating the movement of dual-use items”

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