Saturday, December 29, 2007

Export Compliance - Global Implications at Home

The U.S. Government encourages companies to pursue business with foreign enterprises. However, there are rules in effect that govern such exporting.

Exporting is defined as the business of:

? Sending or taking hardware out of the U.S. or transferring to a foreign person in the U.S.

? Disclosing (oral, email, written, video, or other visual disclosure) or transferring technical data to a foreign person whether in the U.S. or abroad.

? Providing a service to, or for the benefit of a foreign person, whether in the U.S. or abroad This serves as a just reminder that industry needs to be cognizant of what kind of information it discloses to foreign persons. Whether or not you are in the U.S. or visiting overseas, you can only discuss what is authorized on our license.

Keep in mind that exports can and do occur not only during shipments but when hosting foreign visitors, during meetings, tradeshows, plant tours, chat-room discussions, published articles and many other means. You can even export technical items exposed on your desk or otherwise revealed when a foreign visitor tours the facilities. Be sure to review all appropriate publications, your company Technology Control Plan and security policies for compliance issues specific to the licenses.

The government highly encourages business with approved foreign persons and has developed a system for obtaining licenses to do so. If you have any questions about exporting or about existing licenses and TAA's, contact the security office or the contracts manager.

Jeff Bennett is the founder of ISPCert.com. He has written a study manual for the NCMS' Industrial Security Professional Certification. For more information on Jeff's articles and ISP Certification, please visit http://www.ispcert.com



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