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Annex to ASBIS’ Export Compliance Policy

On U. S. regulations

For short overview of the U.S. export control compliance please referrer to “Introduction to Commerce Department Export Controls” in “Export Control Basics” section at: http://www.bis.doc.gov

Commerce Control List (CCL)

The Bureau of Industry and Security (BIS) maintains the Commerce Control List (CCL) within the Export Administration Regulations (EAR), which includes items (i.e., commodities, software, and technology) subject to the export licensing authority of BIS. The CCL does not include those items exclusively controlled for export or reexport by another department or agency of the U.S. Government. In instances where agencies other than the Department of Commerce administer controls over related items, entries in the CCL contain a reference to these controls.

The CCL is contained in Supplement No. 1 to part 774 of the EAR. Supplement No. 2 to part 774 of the EAR contains the General Technology and Software Notes relevant to entries contained in the CCL.

For details please consult EAR database at: http://www.bis.doc.gov

Commerce Country Chart

BIS also maintains the Commerce Country Chart. The Commerce Country Chart, located in Supplement No. 1 to part 738, contains licensing requirements based on destination and Reason for Control. In combination with the CCL, the Commerce Country Chart allows you to determine whether a license is required for items on the CCL to any country in the world.

For details please consult EAR database at: http://www.bis.doc.gov

License Exception

The License Exception is located in part 740 of the EAR. The Supplement No. 1 to part 740 contains the list of Country Groups A, B, C, D and E.

A “License Exception” is an authorization contained in this part that allows the company to export or reexport under stated conditions, items subject to the Export Administration Regulations (EAR) that would otherwise require a license under General Prohibition One, Two, Three, or Eight as indicated under one or more of the Export Control Classification Numbers (ECCNs) in the Commerce Control List (CCL) in Supplement No. 1 to part 774 of the EAR and items subject to the EAR that would require a license based on the embargo policies described in part 746 of the EAR.

In the Supplement No. 1 to part 740 the following countries CUBA, IRAN, NORTH KOREA, SUDAN and SYRIA are included into Country Group E:1 of Terrorist Supporting Countries where any export or re export is prohibited.

For details please consult EAR database at: http://www.bis.doc.gov

Lists To Check

The following lists may be relevant to your export or reexport transaction.

Denied Persons List

A list of individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order is prohibited.

Unverified List

A list of parties where BIS has been unable to verify the end use in prior transactions. The presence of a party on this list in a transaction is a “red flag” that should be resolved before proceeding with the transaction.

Entity List

A list of parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations. The list specifies the license requirements that apply to each listed party. These license requirements are in addition to any license requirements imposed on the transaction by other provisions of the Export Administration Regulations.

Specially Designated Nationals List

A list compiled by the Treasury Department, Office of Foreign Assets Control (OFAC). OFAC’s regulations may prohibit a transaction if a party on this list is involved. In addition, the Export Administration Regulations require a license for exports or reexports to any party in any entry on this list that contains any of the suffixes "SDGT". "SDT", "FTO" or "IRAQ2".

Debarred List

A list compiled by the State Department of parties who are barred by §127.7 of the International Traffic in Arms Regulations (ITAR) (22 CFR §127.7) from participating directly or indirectly in the export of defense articles, including technical data or in the furnishing of defense services for which a license or approval is required by the ITAR.

Nonproliferation Sanctions

Several lists compiled by the State Department of parties that have been sanctioned under various statutes. The Federal Register notice imposing sanctions on a party states the sanctions that apply to that party. Some of these sanctioned parties are subject to BIS’s license application denial policy described in §744.19 of the EAR (15 CFR §744.19).

General Order 3 to Part 736 (page 9)

General Order No. 3 was removed from the EAR in a final rule published on September 22, 2008 (73 FR 54499). 

US and EU Sanctions relative to Russia and Crimea

For details please consult “Lists to Check” section at: http://www.bis.doc.gov

Updated on February 10, 2014