Transcript Document 7117614

NOAA Workshop
on U.S. Export Controls
June 10th & 11th, 2009 – HCHB
July 21st & 22nd, 2009 - Seattle
U.S. Department of Commerce
Bureau of Industry and Security
Deemed Export Compliance
Bernard Kritzer
Director
Office of Exporter Services
[email protected]
June 2009
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Agenda
• Export Controls Overview
• How to Classify Items on the Commerce Control
List
• Foreign National Visitor and Guest Access
Program
• Deemed Exports Overview
• NOAA Deemed Export Compliance Program
• Exercises
• Show how to navigate and use the EAR
June 2009
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BIS is here to help!
•
•
•
•
•
Outreach Activities
Exporter Counseling
Advisory Opinions
Commodity Classifications
Compliance Strategies
June 2009
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Need Assistance?
Bureau of Industry and Security
Outreach & Educational Services
14th St. & Pennsylvania Ave. NW
Washington, DC 20230
Ph. (202) 482-4811
Fax (202) 482-2927
Western Regional Offices
3300 Irvine Avenue, Suite 345
Newport Beach, CA 92660
Ph. (949) 660-0144
Fax (949) 660-9347
96 North 3rd Street, Suite 250
San Jose, CA 95112
Ph. (408) 291-4212
Fax (408) 291-4320
June 2009
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June 2009
6
Bureau of Industry and Security
■ Bureau Mission: to advance
U.S. national security,
foreign policy, and
economic interests

Statutory Authority: Export Administration
Act (EAA) of 1979, as amended; International
Emergency Economic Powers Act, as
amended
Responsibilities: BIS is responsible for
implementing and enforcing the Export
Administration Regulations (EAR), which
regulate the export and reexport of most
commercial and dual-use items.
June 2009

7
The Threat
■ Dangers of illegal technology transfers are very
real:
- WMD Proliferation
- Weapon Design/Manufacture
- Industrial Espionage
■ U.S. economy damaged by illegal technology
transfers.
June 2009
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The Threat
■ Significance: Both national security and
U.S. economy can be seriously damaged by
illegal technology transfers.
■ Damage to the economy can include loss of
large amounts of proprietary R&D done
over many years.
■ Loss of proprietary R&D can result in the
establishment and/or enhancement of
foreign competitors in leading edge
technology sectors.
June 2009
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Origin of the Threat
■ U.S. Intelligence Community has noted:

Collection and acquisition activities from over 56
foreign nations

13 countries assessed to be most aggressive
collectors of U.S. proprietary economic information
and critical technologies

Use of clandestine and illegal methods to collect
technology

U.S. private sector studies estimate loss in the
billions every year
June 2009
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What is being targeted?

Nationally

Biotechnology

Pharmaceuticals

Nanotechnology

Quantum Computing

Advanced Materials

Communications and Encryption Technology

Weapons Systems yet unclassified
June 2009
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Methods Used to Target Technology

Unsolicited emails

Front companies

Liaisons with universities that
have ties to defense
contractors

Recruitment by foreign
intelligence services

National laboratories

Compromise of laptop while
traveling overseas
June 2009

Attending/Hosting
conferences

Relocating R&D facilities
overseas

Circumventing export control
laws

Visiting scientific and research
delegations

Hacking

Downloading information
from your network
12
Deemed Export
Enforcement Facts
■ Since 2004, Export Enforcement has closed over 120 investigations,
involving a deemed export. Many of these investigations resulted in
action being taken or the issuance of a warning letter.

Since 2004, BIS has issued 19 final orders in 17 investigations involving
deemed export violations. This has resulted in over $2 million in
fines.

Approximately one-half of the cases involved Voluntary SelfDisclosures (VSDs) and both commodity and technology exports.

Eight cases involved deemed export violations alone.

Most violations involved unauthorized transfers of Category 3
(Electronics) and Category 5 (telecommunications).
June 2009
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Key Compliance Issues

Since 2004, a central theme that has been identified in the course of
over 120 investigations of deemed exports has been the poor
communications or disconnect between the key compliance actors in
the private sector:
1)
Export Compliance Personnel
2)
Human Resources
3)
Hiring Managers

There were also issues surrounding foreign visitors and the need for
enhanced compliance training.

This is significant for high technology companies because the
investigations identified the fact that many companies maintained
effective programs for commodities but that it did not carry over in
the area of technology.
June 2009
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Technology Control Plan (TCP)
■ The key to technology export compliance is an effective Technology
Control Plan.
■
A TCP should contain the following essential elements:
• Management commitment to export compliance
• Physical security plan
• Information security plan
• Personnel screening procedures
• Training and awareness program
• Self-evaluation program
■
Meaningful compliance is “win-win” because it protects national security
and allows a company to protect its proprietary technical data essential
to R&D and bringing new products to market timely.
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Key Points for Discussion

Successful deemed export compliance incorporate
commodities and technologies.

Successful deemed export compliance also
represents management’s commitment to a holistic
approach, involving successful interaction between
the key stakeholders--export compliance personnel,
hiring managers, and human resources.

Rarely have we seen a deemed exporter fail that
established and maintained a strong TCP, successful
interaction between internal stakeholders, and
meaningful annual assessments of its program.
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Key Points for Discussion

The cost of such compliance is small given the
potential downside loss of millions of dollars of
proprietary technology and compromises to national
security.

Meaningful deemed export compliance also requires
an active partnership between government and all
affected stakeholders.
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Overview of the Export
Administration Regulations
(EAR)
BIS Mission
• To advance U.S. national security, foreign policy,
and economic interests.
– BIS is responsible for implementing and enforcing the
Export Administration Regulations (EAR), which
regulate the export and reexport of most commercial
items.
June 2009
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How Do We Control Exports?
Statutory Authority
• Export Administration Act (EAA) of 1979, as
amended
• International Emergency Economic Powers Act, as
amended
June 2009
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Export Administration Regulations
(EAR)
• Implement the Export Administration Act
• Apply to most commercial items
Broad jurisdiction BUT…
narrow license requirements
June 2009
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Where can you find the EAR
• Code of Federal Regulations
– 15 CFR 730-774
– www.gpoaccess.gov
• Available on-line:
– www.bis.doc.gov
• Order from Government Printing Office
– 866-512-1800 (toll-free)
– www.access.gpo.gov
June 2009
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Why Do We Control Exports?
• National Security
• Foreign Policy
– Anti-terrorism
– Crime control
– Regional Stability
• Non Proliferation
– Nuclear weapons
– Chemical/biological weapons
– Missiles
June 2009
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Who Else is Involved in Export Controls?
Other Regulatory Agencies
Part 730, Supplement 3
•
US Dept. of State - Directorate of Defense Trade Controls
•
US Dept. of Treasury - Office of Foreign Assets Control
•
US Dept. of Energy
•
Nuclear Regulatory Commission
•
US Dept. of Commerce – Patent & Trademark Office
•
US Department of Interior
•
Food and Drug Administration
•
U.S. Department of Commerce –records) Bureau of the Census
(trade statistics and SEDs/AES
•
U.S. Department of Homeland Security – Border and Transportation
Security
– U.S. Customs Service (works with BIS to ensure compliance)
June 2009
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Important EAR Terms
•
•
•
•
•
•
•
Dual-Use
Item
Export
Reexport
Deemed export/reexport
Commerce Control List (CCL)
Export Control Classification Number (ECCN)
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Dual-use Items
• Items that have both commercial and military or
proliferation applications.
• This term is often used informally to describe
items that are subject to the EAR.
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What is an item?
Part 772
June 2009
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What is an export?
• An export is a shipment or transmission of items
out of the United States.
June 2009
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What is a deemed export?
• The release of technology or source code to
foreign national in the US is deemed to be an
export.
June 2009
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What is a reexport?
• A reexport is a shipment or transmission of
items subject to the EAR from one foreign
country to another.
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Technology and Software Exports
and Reexports
• Include transfers regardless of the
method or media
–
–
–
–
–
–
–
–
June 2009
Consultations
Phone conversations
Instruction
Conferences
Application of knowledge
Visual inspections
Disks, blueprints, hardcopy, etc.
Internet, E-mail, Fax
31
Other Important Concepts
• Commerce Control List (“CCL”)
• Export Control Classification Number (“ECCN”)
June 2009
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What does “Subject to the EAR” mean?
§734.2(a)
Items and activities under the regulatory
jurisdiction of the EAR
– Remember there are other government
agencies that administer export controls
“Subject to EAR” does not mean that a license is
automatically required
June 2009
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What is “Subject to the EAR?”
§§734.3-734.5
• Items in the United States
• Some items located outside of the United States
• Activities of U.S. and Foreign Persons
June 2009
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What is “Subject to the EAR”?
Items in the United States
§734.3(a)(1)
• ALL Items in the United States, except:
– Publicly available technology & software (excluding
encryption)
– Items subject to the exclusive jurisdiction of
another federal department or agency
– Literary publications, such as newspapers or
literary works (non-technical in nature)
June 2009
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What is “Subject to the EAR”?
Items Outside the United States
§734.3
• Some items located outside the United States:
– U.S.-origin items wherever located
– Certain foreign-made items, if:
• The value of the U.S. content exceeds the de
minimis percentage
• The foreign-product item is the direct product of
U.S. technology or software
June 2009
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Who is “Subject to the EAR”?
U.S. Persons and Foreign Persons
§734.5
• Certain activities of U.S. persons (§744.6)
– Related to proliferation
• Activities of U.S. or foreign persons prohibited by any
order issued under the EAR.
June 2009
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Overview-Summary
• BIS regulates exports, reexports and certain
transfers of items subject to the EAR in addition to
certain activities of U.S. persons.
• Important terms: Items, export, reexport, deemed
export, CCL & ECCN
• First order of business is to determine whether or
not your transaction is subject to the EAR.
June 2009
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Classification of Items on the
Commerce Control List
Darrell Spires
Engineer
Office of Nonproliferation and Technology
Transfer Controls
Topics of Discussion
• Determining the Export Control Classification
Number (“ECCN”)
– The Commerce Control List (“CCL”)
• Self-Classification
• Official Commodity Classification Request
– SNAP-R
June 2009
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Why are classifications so important?
• Proper classifications prevent:
– Delays in exporting
– Potential violations of the EAR
June 2009
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Commerce Control List (“CCL”)
Part 774, Supplement No. 1
• Contains lists of those items subject to the
licensing authority of BIS
• Each entry is called an Export Control
Classification Number (“ECCN”)
• Most items are described in terms of their
technical parameters
June 2009
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What does Export Control Classification
Number (“ECCN”) tell us?
Part 772
• What items are controlled?
• Why BIS controls the item?
• Which destinations will require a license?
– Country Chart in Supp. 1 to part 738,
• What (if any) list-based license exception
applies?
June 2009
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The Structure of the ECCN
0 A 018
June 2009
0
Category
A
Product Group
018
Type of Control
44
Categories of the Commerce Control List
0 Miscellaneous & Nuclear Materials
Materials, Chemicals,
Microorganisms, and Toxins
1
2 Materials Processing
3 Electronics
4 Computers
5 Part 1-Telecommunication
5 Part 2-Information Security
6 Sensors & Lasers
7 Navigation & Avionics
8 Marine
June 2009
9 Aerospace & Propulsion
0 A 018
45
Product Groups of the Commerce
Control List
A Systems, Equipment & Components
B Test, Inspection & Production Equipment
C Materials
D Software
E Technology
0 A 018
June 2009
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Type of Controls Associated with Entry
0
1
2
3
National Security Reasons
Missile Technology Reasons
Nuclear Nonproliferation Reasons
Chemical & Biological Weapons Reasons
Anti-terrorism
Crime Control
Regional Stability
9
Short Supply
0 A 018
UN Sanctions
Surreptitious Listening
June 2009
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Most of the time related items are
grouped in series
Materials
Equipment,
assemblies
and
components
June 2009
Technology
Test,
inspection
and
production
equipment
Software
48
How to Read an ECCN entry
• Number and Heading
• License Requirements
– Reasons For Control
• License Exceptions (List-based)
• List of Items Controlled
– Units
–
–
–
June 2009
Related Controls
Related Definitions
Items
49
How to Read an ECCN
Heading:
ECCN &
Description
June 2009
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How to Read an ECCN
License
Requirements:
Reasons for
Control
June 2009
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How to Read an ECCN
License
Exceptions:
List-Based
June 2009
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How to Read an ECCN
List of
Items
Controlled:
Units
Related
Controls
Related
Definitions
Items
June 2009
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June 2009
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Technology and Software
Classification
• Review Commerce Control List (CCL)
• Identify Export Control Classification
Number (ECCN)
• In most cases, technology tied
directly to hardware “development”,
“production”, or “use”
• Refer to General Technology and
Software Notes (Supplement No. 2 to
Part 774)
June 2009
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General Technology Note
The export of “technology” that is
“required” for the “development”,
“production”, or “use” of items on
the Commerce Control List is
controlled according to the
provisions in each category.
June 2009
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Technology and Software ECCNs
5A101
Telemetry Equipment
5D101
Product
Groups D
and E
Telemetry Software
5E101
Telemetry Technology
June 2009
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Technology and Software Terms
• Development
• Production
• Use
• Required
June 2009
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"Development"
• "Development" is related to all
stages prior to serial production,
such as: design, design research,
design analyses, design concepts,
assembly and testing of prototypes,
pilot production schemes, design
data, process of transforming design
data into a product, configuration
design, integration design, layouts
June 2009
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"Production"
• Means all production stages, such
as: product engineering,
manufacture, integration, assembly
(mounting), inspection, testing,
quality assurance.
June 2009
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"Use"
• Operation, installation (including
on-site installation), maintenance
(checking), repair, overhaul and
refurbishing.
June 2009
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"Required"
• As applied to "technology" or
"software", refers to only that
portion of "technology" or "software"
which is peculiarly responsible for
achieving or extending the controlled
performance levels, characteristics
or functions. Such "required"
"technology" or "software" may be
shared by different products.
June 2009
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General Software Note
Supplement No. 2 to Part 774
• Sold from stock at retail selling points without
restriction, by means of:
1.
2.
3.
4.
Over the counter transactions;
Mail order transactions;
Electronic transactions; or
Telephone call transactions; and
• Designed for installation by the user.
June 2009
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EAR99 Items
• Items that are not specifically listed on the
Commerce Control List yet subject to the EAR,
use the designation EAR99 in place of an ECCN.
• This designation may be found at the end of every
category of the CCL:
“EAR99 Items subject to the EAR that are not
elsewhere specified in this CCL Category or in
any other category in the CCL are designated
by the number EAR99.”
June 2009
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How can you obtain the ECCN of your
item?
1. Ask the manufacturer, but verify…
2. Self-classify
•
Work with company engineer or someone who knows
the item
3. Submit formal classification request to BIS
June 2009
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An Approach to Self-Classifying Items
• Do an index comparison (good starting
point)
You need to understand the functions &
characteristics of the item!
June 2009
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Helpful Hints for Self-Classification
• Get started early classifying your items
• Understand organization of CCL and
approaches to classifying items
• Understand the technical parameters of your item
June 2009
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How to Request a Classification
File using SNAP-R (or BIS-748-P)
• “Best guess” ECCN
• Maximum of six items per request
• Item details
–
–
–
–
Manufacturer
Model/Part number
Applications
Specifications
• Include detailed technical specifications
– Pictorial illustration, e.g. sales brochures
June 2009
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Classification- Summary
Determining an ECCN
1. Check with the Manufacturer
2. Work with company engineer/someone who
knows the item
• CCL is organized in a logical manner
• ECCN entries are based on the technical
parameters of an item and contain a wealth
of information regarding export controls
3. Submit formal classification request to BIS
June 2009
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Determining License
Requirements based on ECCN
and Destination
Commerce Country Chart
Part 738, Supplement No. 1
• Reasons for Control/Country Chart
• If there is:
– “X” in the box indicates a license requirement
– No “X” in the box indicates no license
requirement
June 2009
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Structure Commerce Country Chart
When the Destination and the Reason for Control Meet, Ask Yourself…
Is there an “X” in the box?
June 2009
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No License Required
(“NLR”)
• You may use NLR for:
– EAR99 items, or
– ECCNs where there is no “X” on the Country Chart
under reason(s) for control; and
– When the transaction does not require an export
license based on any other licensing requirement
(e.g., end-use/user requirements)
June 2009
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Summary-Determining Licensing Requirements
based on ECCN & Destination
• “X” in the box indicates a license requirement
• No “X” in the box indicates no license
requirement
June 2009
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License Exceptions
Toni Jackson
Export Administration Specialist
Office of Exporter Services
There is an “X” in the Box…
What do
I do?
June 2009
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Topics of Discussion
• What is a License Exception?
• Restrictions
• List Based License Exceptions
June 2009
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What is a License Exception?
Part 740
An authorization that allows you to
export or reexport, under stated
conditions, items subject to the EAR
that would otherwise require a
license.
June 2009
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When can’t you use a License
Exception?
§740.2
• Authorization has been suspended or revoked
• Export subject to a General Prohibition that is
not eligible for License Exceptions.
• Surreptitious Interception Devices
• Crime control items to most destinations
• Most Missile Technology control items
• Embargoed destinations, in most instances
For Full list Refer to
§740.2
June 2009
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The way the EAR sees the world…
Country Groups
Supplement 1 to Part 740
Group A: Regime Members
Group B: Less Restricted
Group D: Countries of Concern
Group E: Terrorist Supporting
June 2009
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Commerce Control List-Based
License Exceptions
Availability Based on ECCN
–
–
–
–
Shipments to B Countries (GBS)
Civil End Users (CIV)
Limited Value Shipments (LVS)
Technology and Software Restricted
(TSR)
– Computers (APP)
June 2009
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GBS Group B Shipments
§740.4
• Shipments to Country Group B
• Commodities requiring a license to the
ultimate destination for national security
reasons only
June 2009
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CIV Civil End-Users
§740.5
• Country Group D:1, except North
Korea
• Items that require a license to the
ultimate destination for national
security reasons only
• Civil end-uses and end-users
– No military or proliferation endusers/uses
June 2009
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LVS Limited Value Shipment
§740.3
•
•
•
•
Country Group B
Commodities
Net value cannot exceed LVS value limit
Annual value restriction
– 12 x LVS value of same ECCN to same
consignee
• Single shipment
NO splitting orders!
June 2009
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TSR Technology & Software
Under Restriction
§740.6
• Country Group B
• Technology & software requiring a
license to the ultimate destination
for national security reasons only
• Prior to use, written assurance
required from consignee
June 2009
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TSR Written Assurance
• Letter, other written communication,
licensing agreement, fax
• No written assurance -- No TSR
June 2009
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Summary-License Exceptions
• Make sure your deemed export requires a license
(i.e. there is an “X” in the box), before reviewing
the License Exceptions.
• Before going to a specific license exception, make
sure there are no restrictions.
• Each exception is unique, make sure you meet of
all of the criteria.
June 2009
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Deemed Exports
William Arvin
Senior Export Policy Analyst
Office of Exporter Services
Deemed Exports:
Definition
• Release of
•
•
•
•
technology or source code
that is subject to the EAR
to a foreign national
in the United States (EAR
§ 734.2(b)(2)(ii)).
• Release is “deemed” to be an
export to
foreign national’s
home country
June 2009
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Technology or Source Code
Possible Release Methods
• Tours of laboratories
• Research, development, &
manufacturing activities
• Foreign students or scholars
conducting research
• Hosting a foreign scientist
June 2009
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Deemed Export Rule Does Not
Apply To:
• United States Citizens;
• Permanent Resident Aliens
(i.e., “Green Card” holders); and
• Protected individuals under 8 U.S.C.
1324b(a)(3). Protected individuals
include political refugees and political
asylum holders.
June 2009
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Country of Origin
(Permanent Residency)
Release of technology to a foreign national of
one country, say India, who has obtained
permanent residency in another, say the
U.K., is treated as if the technology transfer
were being made to the U.K. and licensing
requirements would be the same as for a
British national in the U.K.
If the Indian national becomes a British
citizen, transfers of technology would
be viewed as transfers to the U.K.
June 2009
92
Country of Origin
(Dual Citizenship)
As a general principle, a
foreign national’s most
recently obtained citizenship
governs the licensing
requirement.
If an Indian foreign national
becomes a citizen of the U.K.
but retains Indian citizenship, the
most recent citizenship is with
the U.K. and releases of
technology would be viewed as
releases to the U.K.
June 2009
93
Deemed Exports
License Requirements
• Is the technology (or source
code) subject the EAR?
• Is a license required?
June 2009
94
Technology Not Subject to the EAR
• Publicly available (EAR § 734.7)
• Generally accessible to the interested
public
• Periodicals, books, print, electronic
other media forms
• Libraries (university, public etc)
• Released at open conferences
June 2009
95
Technology Not Subject to the EAR
• Product of fundamental
research (EAR § 734.8)
•Basic and applied research
where resulting information
is ordinarily published and
broadly shared within
scientific community
June 2009
96
Technology Not Subject to the EAR
• Educational information (EAR §
734.9)
• Released by instruction in catalog courses
• Associated teaching laboratories of academic
institutions
• Patent information (EAR § 734.10)
• Public information available on patent
application
June 2009
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Technology Not Subject to the
EAR (Cont.)
• Technology subject to the
exclusive export licensing
jurisdiction of another agency
• Directorate of Defense Trade
Controls
• Nuclear Regulatory Commission
• Department of Energy
June 2009
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Deemed Export License Requirements
• Usually Commerce Control List Based
• Other license requirements based on
• End use
• Embargoed destinations
• Entity List
June 2009
99
Deemed Export License Requirements
• Classify the commodity
• Second character of ECCN will be A, B
or C
• Look for a related software (D) or
technology (E) ECCN usually in the
same category
• Most software and technology ECCNs
apply to software or technology for
“development,” “production,” or
“use.”
June 2009
100
Deemed Export License Requirements
• “Development” – all stages prior to
serial production
• “Production” – all production stages
including inspecting and testing
• “Use” – Operation, installation,
maintenance, repair, overhaul and
refurbishing
• E.g., Providing operating instruction for
a machine by itself is not a transfer of
use technology for that machine
June 2009
101
Deemed Export License Requirements
• Determine the classification of the
technology or software
• Identify reasons for control
• Determine foreign national’s home
country
• Check country chart to see if a
license is required to that country.
June 2009
102
The Deemed Export Application
• Detailed letter of explanation
• Comprehensive resume
• Complete job description
• Foreign national’s particular
qualifications
• Safeguards to restrict access to that
approved (Technology Control Plan)
June 2009
103
Letter of Explanation
• Identities of all parties to the transaction
• Exact project location (where the technology or
software will be used)
• Type of technology and scope
• Availability abroad of comparable foreign technology
or software
• Form in which the technology will be released and the
uses for which the technology will be employed.
• Applicant’s internal technology control plan
June 2009
104
Foreign National’s Resume
• Include all educational institutions
attended beyond high school
• Street addresses
• Degrees or certificates received.
• All positions held
• Employers’ names and street addresses
• Brief description of work done.
June 2009
105
Foreign National’s Resume (Cont.)
• Account for all time since from high school
graduation
• Present in month and year format
• No gaps greater than 30 consecutive days.
• Include brief abstracts of all scientific and
technical papers published, and
presentations at scientific and technical
conferences.
June 2009
106
Technology Control Plan
•
The requirement for a technology control
plans are a standard condition found in
deemed export and technology exports
licenses.
June 2009
107
Technology Control Plan (Cont)
• Essential elements:
•
•
•
•
•
•
June 2009
Physical security plan
Information security plan
Personnel screening procedures
Training and awareness program
Self evaluation program
Corporate commitment to export
compliance
108
Helpful Information
• Does the foreign national:
• Have strong ties to the U.S. (e.g., family
here, home ownership, etc.) and / or
• Intend to become a U.S. citizen?
• What ties does the foreign national have
to his / her country of origin?
• What special benefits or expertise the
foreign national brings to the applicant?
June 2009
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BIS - Application Review
• Verify classification of technology
• Review licensing requirements & license
exceptions based on home country
• Assess appropriateness of job description,
responsibility, title
• Assess appropriateness of education level
and field to technology & end-use
• Determine reasons for control for correct
referrals
June 2009
110
License Exceptions for Deemed
Exports
• CIV: Civil End Use (EAR § 740.5)
• ECCN 3E002 technology.
• APP: Adjusted Peak Performance (EAR
§ 740.7)
• ECCNs 4D001 and 4E001 software
and technology
• Both require foreign national review
June 2009
111
Foreign National Review (FNR)
Sections 740.5 & 740.7
• Applicant must submit FNR request
before disclosing technology under
license exceptions CIV and APP.
• Request must provide same information
on the foreign national as a license
application.
• Faster review than license applications
June 2009
112
License Exceptions for Deemed Exports
• TSR: Technology and Software
Under Restriction (EAR §
740.6)
• Applies to technology and
software under national security
only for country group “B”
nationals.
• Letter of assurance required
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113
Deemed Export Application
Statistics FY2008-- Results
• Total applications processed
1252
• Approvals
1147 (91%)
• RWA’s
101 (8%)
• Denials
4 (>1%)
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114
Deemed Export Application
Statistics FY2008– Nationalities
• 57% People’s Republic of China
• 10% India
• 7% Russia
• 6% Iran
• 5% United Kingdom
• 1% Germany
• 2% Others
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115
Deemed Export Contacts
Deemed Exports and Electronics Division
Brian Baker
Director
202-482-5534
[email protected]
Kurt Franz
Senior Export Policy Analyst
202-482-2278
[email protected]
Bob Juste
Senior Electrical Engineer
202-482-2845
[email protected]
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