Transcript Export Compliance PPT Presentation

Network Centric Operations
Industry Consortium
Export Compliance
Ginger Carney
Director, Export Compliance
NCOIC
June 2008
Approved for Public Release
Distribution Unlimited
NCOIC-ExpComp
© Copyright 2008 NCOIC - All rights reserved
NCOIC Technical Team Work
assists
customers in obtaining
interoperable solutions
NCOIC Technical Team Work
 Identify standards used in network centric operations
 ‘Operations’ – military, civil, humanitarian
 Identify use cases, patterns of use
 Analyze the use of those standards
 Apply to identified use cases
 Conduct gap analyses, harmonization of various
requirements, etc.

Ultimate goal is an architectural reference model for
stakeholder communities
© Copyright 2008 NCOIC - All Rights Reserved
Government Agencies Regulate Exports
assists
customers in obtaining
interoperable solutions
Government Agencies Regulate Exports
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Australia – Minister for Defence
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Germany – Federal Ministry for Economics
Denmark – Ministry of Justice
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Israel – Ministry of Defense (SIBAT)
Finland – Ministry of Defense,
Council of State
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Italy – Ministry for Foreign Affairs
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France – Secretary General of
National Defense, Commission for
the Study of Export of War Material
(CIEEMG); Service des Titres du
Commerce Extérieur (SETICE)
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Netherlands – Ministry of Economic Affairs
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Poland – Ministry of Defense
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Spain – Ministry of Economy & Taxes
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Sweden – Ministry of Foreign Affairs,
Ministry of Defense
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Switzerland – Federal Office for Foreign
Economic Affairs
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UK – Dept of Trade & Industry
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US – Dept of State; Dept of Commerce
© Copyright 2008 NCOIC - All Rights Reserved
When Does
an Export Take in
Place?
assists
customers
obtaining
interoperable solutions
When Does an Export Take Place?
 Physical:
– Shipment of
hardware or data
– Defense services
– Handcarry
 Verbal
 Electronic
© Copyright 2008 NCOIC - All Rights Reserved
Intangible Exports
assists
customers in obtaining
interoperable solutions
Intangible Exports
Verbal:
 Plant visit
 Visit to overseas
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Electronic:
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Fax
E-mail
Internet
Shared collaborative
space, blog, wiki
Electronic media
(CDs, USB drives,
PDAs)
customer/plant
Joint venture
Meeting

Trade show
Presentation of
paper at tech
symposium
Phone call © Copyright 2008 NCOIC - All Rights Reserved
Topics for Open Discussion
assists
customers in obtaining
interoperable solutions
Topics for Open Discussion
 Open Standards, and their patterns of use, technical merit, specification, or

evaluation, provided such discussions are not centered on military
applications, contracts, or programs. (Identifying WHAT)
Technical/non-technical materials, information obtained from public domain
or open source literature with unlimited distribution (provided such
discussions are not centered on military applications, contracts, or
programs). Includes, is not limited to, information from:
– Open websites
– Publications (open subscription), conferences/seminars available
to public,
– General scientific information
– Governance and non-technical information, including but not
limited to schedules, plans, working group processes, policies,
and procedures (not related to manufacturing or production),
roadmaps, statements-of-work, action items, status reports,
budgets, meeting and conference call notes (if non-technical), and
other similar items.
© Copyright 2008 NCOIC - All Rights Reserved
Restricted
Topics (US-ITAR)in obtaining
assists
customers
interoperable solutions
Restricted Topics (US-ITAR)
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Discussion on HOW open standards, patterns of use, etc.,
are applied to military programs
Other information from public source, but discussed with
regard to specific military application, programs, or
contracts (US or other government)
Information sourced from a website, access to which is only
possible with a Government sponsor
Information on specific military applications and/or
programs
(From the US) FOUO information
(From other nations) Information marked as restricted, on
case-by-case basis
Classified data or information
Manufacturing know-how
© Copyright 2008 NCOIC - All Rights Reserved
Violations and Penalties
assists
customers in obtaining
interoperable solutions
Violations and Penalties
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Varying levels of assessment among
different national regulations
All national regulations impose penalties
Civil – administrative violations
Criminal – intent to circumvent the law
– More significant penalties

In the US, as in other countries, penalties
assessed in the millions of dollars/currency
– Lost revenue due to suspension from Government
contracting (US)
© Copyright 2008 NCOIC - All Rights Reserved
Our Responsibilities
assists
customers in obtaining
interoperable solutions
Our Responsibilities
As an NCOIC participant, you are responsible to
 Abide by your country’s export
regulations
 Abide by your organization’s
export regulations
 Know contact information for
your organization’s export
compliance official
 Protect restricted information
appropriately
© Copyright 2008 NCOIC - All Rights Reserved