Part of the Trade Compliance Practitioner Certification Series
Course Summary
This practitioner-level course examines the authorization types available for exports and imports of regulated hardware, technical information, software, and services under both direct commercial sales and Foreign Military Sales programs. This course also addresses permanent and temporary nature of transactions. The course provides an overview of these areas in relation to the relevant U.S. compliance regimes, including the Export Administration Regulations, the International Traffic in Arms Regulations, and Office of Foreign Assets Control-administered sanctions and embargoes.
The training provides detailed guidance for implementing the appropriate authorization for transactions that may involve multiple authorization types, as well as different regulations depending on the activity. This course also discusses which business functions may have the relevant information required to determine authorization needs, such as program management, contracts, business development, procurement, and logistics.
Learning Objectives
The broadest objective of this course is to enable learners to recognize the different types of authorizations and their applicability to ensure your transaction is compliant. This objective is satisfied when they can:
Trade-Specific Objectives
Understand the implementation requirements for the different types of authorizations under the ITAR and the EAR.
Recognize when multiple authorizations are needed for a transaction to be compliant.
Identify the authorization management and recordkeeping requirements for the different types of authorization.
Remember that different business functions play a role in authorization management and recordkeeping.
Distinguish and/or differentiate the requirements between permanent and temporary transactions.
Role-Specific Objectives
Understand that they may be responsible for determining the appropriate authorization for a transaction.
Recognize that they may be asked to approve the use of a company-certified authorization.
Realize that they may be responsible for preparing and submitting formal authorization requests.
Understand that they may be responsible for ensuring the appropriate recordkeeping is maintained for an authorization.
Course Outline
Introduction to U.S. Export Licensing for Practitioners
Regulatory Overview
The Arms Export Control Act
Layout of the ITAR
Registration Under the ITAR
The Export Administration Act
Layout of the EAR
Subject to the EAR
Jurisdiction and Classification
Regulated Activities
Authorizations
Authorization Management
Customs Clearance
Trade Compliance Programs
Jurisdiction and Classification
Regulated Activities
Key Definitions
U.S. and Foreign Persons – ITAR
U.S. and Foreign Persons – EAR
Export
Defense Article
Item
Technical Data
Technology
Defense Service
Reexport – ITAR
Reexport – EAR
Retransfer (ITAR)
Temporary Import (ITAR)
Temporary Export (ITAR)
Public Domain
Significant Military Equipment (ITAR)
Empowered Official (ITAR)
Subject to the EAR (ITAR)
Transfer (EAR)
Dual-Use
Country Groups
Military Commodity
Activities That Are Not Exports, Reexports, or Transfers
Activities That Are Not Deemed Reexports
End-User and End-Use Considerations
Receipt of Licenses and Eligibility Under the ITAR
Interpreting ITAR 126.1(d)/(e)
Overview of the EAR General Prohibitions
Embargoed or Sanctioned Destinations Under the EAR
End-Use and End-User Controls Under EAR Part 744
Red Flag Indicators
Denied Persons
Restrictive Trade Practices and Boycotts
Types of Items and Activities
Internal Activities
Visitors
Post-Export Activities
De Minimis
Foreign-Produced Direct Product Rule
Authorizations
ITAR Authorizations
DSP-5 Licenses
Part 130 Requirements
ITAR – Deemed Export/Foreign Person Employment Licenses
Technical Data Licenses
Limited Defense Services Licenses
Offshore Procurement Licenses
DSP-73 Licenses
DSP-85 Licenses
USML Paragraph (x)
DSP-94
Part 124 Agreements
Types of Agreements
Parties to an Agreement
Determining Value of Part 124 Agreements
Use of Foreign-Person Contract Employees
Elements of an Agreement Package: Transmittal Letter
Elements of an Agreement Package: Proposed Agreement
Reporting on Exports of ITAR Technical Data and Defense Services
Post-Approval Activities for Part 124 Agreements
EAR Recordkeeping Requirements
Export Control Document
Customs Clearance
Trade Compliance Programs
Elements of an Effective Trade Compliance Program
Topics to be Addressed in a Trade Compliance Program
U.S. Government Expectations
Identifying and Disclosing Potential Violations
What Constitutes a Violation Under the ITAR
Consequences of Noncompliance with the ITAR
Notification of Potential Violations Within Your Company
Notification of Potential ITAR Violations to the U.S. Government
Managing Disclosures
Identifying When a Disclosure Should Be Made
Documenting Decision-Making Process
Tracking Implementation of Corrective Actions
Compliance and Enforcement Actions
Debarment/Ineligibility Status
Consent Agreements
Settlement Agreements
Training Summary
Target Audience
Employees who are responsible for determining licensing requirements and obtaining the appropriate authorization
Employees who are responsible for utilizing exemptions and exceptions under the regulations
Employees who play a role in authorization management such as recordkeeping and tracking of activities
Employees who are responsible for managing or overseeing trade compliance activities in other business functions such as classification and export clearance
Course Duration: 7 hours
Certificate of Completion: George Mason University
Subscription Options
You have the choice of making a one-time annual payment of $470.00 or electing to be billed monthly at a rate of $39.00 for 11 months following your initial payment.
If you choose the monthly payment option, the recurring payments will be processed by PayWhirl. If you choose the one-time annual payment option, your payment will be processed securely using Authorize.net, a Visa solution.
$470.00/Year (USD)
$39.00/Month (USD)
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