Question: Can anyone advise the recordkeeping requirements for a deemed export? Iunderstand the requirements for an item controlled by a license. Am moreinterested in a non-controlled EAR99 or something under a license exception. Are exporters required to keep records of e-mails, drawing transfers,downloads of source code, etc. for any deemed export which is not acontrolled […]
Question:My company currently manufactures controlled product in the UK and had to obtain a license to release the controlled technology to personnel from our UK facility. I am trying to put a process in place for the UK that would limit access to the controlled technical data to non UK personnel and visitors to our […]
Question: A student is looking to gain a 6 month co-op at our company. Thisstudent is here in the US on a student VISA and is a citizen of China.Currently, all our parts are classified as EAR99. In the past we didproduce some parts that fell in category 3 and 5 on the EAR, which […]
We would like to know how other companies screen visitors for the purpose of controlling deemed exports? Is proof of citizenship required? or are visitors simply asked to please indicate their country of citizenship without demonstrating proof?
How do you limit access to your foreign nationals (say in China) to controlled technology information that may be available on the internal company web site?
We are interested giving access to portions of our ERP system to a Foreign National Employee. I am suppose to review what we can and cannot release incase it would be controlled for export. Besides general government export controls on controlled technology the other thing I thought of is any of our defense contracts and […]
We are working on building a technology control plan for our company. Does anyone have one they are willing to share?
How have others identified the foreign nationals affected by the deemed export rule, within their organization, while avoiding the appearance of discrimination? For example, have any of you sent a blanket email to all employees within your organization asking for their country of last citizenship? I could really use some feedback on this. Thanks
We are beginning to review our risks and develop policies and procedures related to deemed exports and technology transfers. Does anyone have checklists or other helpful tools that would help us think about the issues to address, e.g. HR questionnaires for foreign national employees, Engineering or production questionnaires to help compliance get a handle on […]
There was an article in the Washington times on Chinese students and espionage. While the article was a bit conspiracy theory, we all know why having a deemed export policy and program in place for foreign nationals is important. It is understood that companies should be screening for foreign nationals (candidates for hire and visitors), […]
Question: How and when does your corporation identify foreign national employees for deemed export concerns? We are trying to work on our deemed export compliance and are experiencing some pushback from our HR department on what we can ask, etc.
Does anyone have a Foreign National Program developed for foreign national visitors and guests that can access company facilities which may have controlled products or controlled technology to ensure that they are adhering to Export Administration Regulations (EAR) controls that prevents inappropriate release or transfer of controlled technology to foreign nationals?
