BIS Revised almost all sections of the Export Regulations in September 2016.
Most companies are impacted.
STEPS to take:
Ensure personnel review changes against your activity.
INCLUDE any hardware, software and technology that you may export, end users/end use.
Include pending fulfillment orders.
Ensure compliance by:
Conducting ECCN review
Update product classifications
Check your systems, correlate ECCN and updated classifications against all system
Active export licenses – evaluate
Does a license exception apply against updated regs?
It is possible that license(s) may need to be de-activated and use license exception or EAR99.
740.17 ENCRYPTION COMMODITIES, SOFTWARE AND TECHNOLOGY (ENC)
semi-annual reporting requirements 2/1/17 and 8/1/17 be prepared
Exporters have affirmative responsibility to be in compliance.
Training outside and internal – seek
Export import compliance can setup internal training site for you and save you money on training and internal audit compliance activities.