Export Enforcement: Policing the Avenues of Trade

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5. Incorrect AES FilingAutomated Export System (AES) collectsElectronic Export Information (EEI).• EEI required for:– Commodities over $2500 in value or– Commodities which require a license or– Commodities* destined for Cuba, Iran, NorthKorea, Sudan, and Syria.• Filing Timeframes: 2 o prior (Air) 24 o prior (Ship)
VoluntarySelf-DisclosuresYou find a problem…do you really want to turn yourself in?– Confess early and often…before we hear about it• Might not be a violation or just a Warning Letter– Significant Penalty Mitigation…half-price sale– Tell the truth, the WHOLE truth…– What’s the plan: How will you avoid a repeat?Or do you roll the dice?– Play the odds…– If you are a manager - Sarbanes-Oxley Implications…
Page 1 and 2: Export Enforcement: Policingthe Ave
Page 3 and 4: Export Enforcement…task is to pre
Page 5 and 6: Export Enforcement Field Offices•
Page 7 and 8: Why do we need controls onDual-Use
Page 9 and 10: Improvised Explosive Devices• P2
Page 11 and 12: Mayrow Case IndictmentUNITED STATES
Page 13 and 14: Top Cape TechnologiesCape Town Sout
Page 15 and 16: The CommoditiesTriggered Spark Gap
Page 17 and 18: WMD Use - Spark GapsCan be used as
Page 19 and 20: The Diversion Scheme…X$$$$$$
Page 21 and 22: UNITED STATES DISTRICT COURTFOR THE
Page 23 and 24: What actions might makea case Crimi
Page 25 and 26: Criminal PenaltiesExport Administra
Page 27 and 28: Administrative PenaltiesIEEPA ENHAN
Page 29 and 30: “This is a fine mess you’vegott
Page 31 and 32: 2. Ignoring Red FlagsAsk yourself:
Page 33: 4. Non-Compliance withLicense Condi
Page 37 and 38: True or False?You shouldn’t conta
Page 39 and 40: A Shared ResponsibilityKeeping the

Export Enforcement: Policing the Avenues of Trade

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