Export Compliance Program
Having a strong Internal Control Program ("ICP") for export compliance is the initial step to ensure that exports and export decisions are consistent with the regulations. Compliance program governs the actions of senior management, logistics departments, international sales & marketing teams, R&D units, Engineering, Human Resources and other departments regarding the export of commodities, international transfer of software and technical data as well as hiring and hosting the nonU.S. nationals. Essential elements of the program provide checks and safeguards at key steps to better manage the overall export process.
Technology Transfer Compliance
In today's world, global collaborative design, development, production and outsourcing activities take place more frequent than they ever did before. Often these activities require the transfer of certain technologies and software to foreign entities. Transfer can take the form of sharing skills, knowledge, methods of manufacturing, samples of manufacturing and facilities with customers, subsidiaries, subcontractors, consultants, universities and partners located abroad.
Deemed Export
Research & Development ("R&D") activities performed abroad by the U.S. based companies, university collaborations, employing non-U.S. nationals for the technical positions, exchanging scientists and technical publications contribute to the economic development in many ways. However, the U.S. Government views the technology and software source code as exported whenever they are released to a non-U.S. national visually, verbally or via any other method whether in the U.S. or abroad, namely deemed export and deemed re-export. Similarly, an export occurs when employees, having obtained personal knowledge or technical experience regarding controlled technology and software source code in the United States, apply that knowledge or experience abroad.
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