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  #1 Myles Leon on 25 May 12

   

  Following these three measures: (1) Creating the right Culture; (2) Preparing a Risk Management System together with (3) Building an interior Control Framework will not guarantee success of the CCO. But certainly following these steps can provide the robust tools required. Good luck!
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  Several years ago while serving for a defense contractor's export concurrence officer, I was approached by the business development manager. She stated that the company was pursuing a contract with a foreign country to supply a defense material. The product had both military together with civilian application. In the following case, they were pursuing a contract for any material with a civil application. She rationalized that since transaction would not be described as a defense article, the company should never need to seek a great export license.
  
  Though there's guidance for what and how to export, many exports issues are unique and are probably not fully understood by defense contractors. As examples, recently a company was fined for violating an export law by delivering a controlled chemical. With another case, a company was billed with providing technical drawings to a foreign country. A few years ago, Chinese officials downloaded technical information from a great American defense contractor employee's laptop computer without his knowledge. The employee faced charges even though he did not willingly provide the data. He had produced the computer and technical information to China without approval. Lack of understanding in the above cases did not provide a good defense. The lesson is that though the government values international business, US companies must understand export laws and operate within them.
  
  In the above cases, the individuals involved can have prevented violations had they understood ways to identify technical data with export controls. Such information is available in the International Traffic within Arms Regulation (ITAR). The ITAR contains the country Munitions List (USML). The USML can be a listing and explanation of export controlled defense items and services. Also, those mixed up in above offenses may don’t you have understood the definition involving export. An export can be explained as providing technical data to a non-US person. This can be carried out by shipping items, verbal and written communications, messenger product and etc. It also includes delivering a technical item or service overseas, providing information on a paper and through multi-media presentations. Exports can also become by a non US person viewing controlled home elevators an unattended computer display. In all situations, US Persons should protect and control the defense products and services according to the ITAR.
  
  This ITAR states, "Any person who engages in the united states in the business with either manufacturing or exporting defense articles or furnishing defense services must register... ". This direct wording fails to leave much room for any other interpretation. All US persons or organizations linked to making Defense articles or providing defense services must register while using the State Department's Directorate with Defense Trade Controls (DDTC).
  
  Furthermore, the Defense Federal Acquisitions Regulation (DFAR) states, "It is the contractor's responsibility to comply with all applicable laws and regulations regarding export-controlled items. " It can be in the company's best interest to learn export laws and how it relates to the organization's mission. The responsibility to identify export controlled information and provide proper protection falls exclusively relating to the organization. money laundering

   

  <div class="cArrow"> </div><div class="cContentInner">Following these three measures: (1) Creating the right Culture; (2) Preparing a Risk Management System together with (3) Building an interior Control Framework will not guarantee success of the CCO. But certainly following these steps can provide the robust tools required. Good luck! <br />.<br />Several years ago while serving for a defense contractor's export concurrence officer, I was approached by the business development manager. She stated that the company was pursuing a contract with a foreign country to supply a defense material. The product had both military together with civilian application. In the following case, they were pursuing a contract for any material with a civil application. She rationalized that since transaction would not be described as a defense article, the company should never need to seek a great export license. <br /> <br /> Though there's guidance for what and how to export, many exports issues are unique and are probably not fully understood by defense contractors. As examples, recently a company was fined for violating an export law by delivering a controlled chemical. With another case, a company was billed with providing technical drawings to a foreign country. A few years ago, Chinese officials downloaded technical information from a great American defense contractor employee's laptop computer without his knowledge. The employee faced charges even though he did not willingly provide the data. He had produced the computer and technical information to China without approval. Lack of understanding in the above cases did not provide a good defense. The lesson is that though the government values international business, US companies must understand export laws and operate within them. <br /> <br /> In the above cases, the individuals involved can have prevented violations had they understood ways to identify technical data with export controls. Such information is available in the International Traffic within Arms Regulation (ITAR). The ITAR contains the country Munitions List (USML). The USML can be a listing and explanation of export controlled defense items and services. Also, those mixed up in above offenses may don’t you have understood the definition involving export. An export can be explained as providing technical data to a non-US person. This can be carried out by shipping items, verbal and written communications, messenger product and etc. It also includes delivering a technical item or service overseas, providing information on a paper and through multi-media presentations. Exports can also become by a non US person viewing controlled home elevators an unattended computer display. In all situations, US Persons should protect and control the defense products and services according to the ITAR. <br /> <br /> This ITAR states, "Any person who engages in the united states in the business with either manufacturing or exporting defense articles or furnishing defense services must register... ". This direct wording fails to leave much room for any other interpretation. All US persons or organizations linked to making Defense articles or providing defense services must register while using the State Department's Directorate with Defense Trade Controls (DDTC). <br /> <br /> Furthermore, the Defense Federal Acquisitions Regulation (DFAR) states, "It is the contractor's responsibility to comply with all applicable laws and regulations regarding export-controlled items. " It can be in the company's best interest to learn export laws and how it relates to the organization's mission. The responsibility to identify export controlled information and provide proper protection falls exclusively relating to the organization. <a href="http://www.compliancemanageruk.com" rel="nofollow">money laundering</a></div>

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