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EAR License Exceptions: Learning By Doing Exercises

Below you will find the exercises covered in our EAR License Exceptions: Learning By Doing.

 

These exercises will be discussed during the first webinar in the series on October 17, 2017. A second set of exercises will be sent to attendees a week prior to second webinar in the series on October 26, 2017.

 

Instructions: Please answer the questions below to the best of your availability prior to the webinar. Assume that all commodities, software and technology described below are subject to the EAR. Further, if additional information is needed to answer the questions below, please identify the questions that should be asked.  

 

Question #1: RoboInterceptor LLC, founded in 2010, is a private company headquartered in Newport Beach, California, that provides innovative, robust and cost-effective solutions and products for various markets such as intelligence agencies, law enforcement agencies, telecom and internet service providers. One of its main product lines is the LI-2017 system which provides lawful interception solutions for cellular, landline and data networks. RoboInterceptor has been marketing this product line exclusively to U.S. law enforcement and intelligence agencies; however, it has just received an inquiry from the UK’s National Crime Agency, which is the UK’s lead agency against organized crime, human/weapon/drug trafficking, and cyber-crimes. RoboInterceptor has self-classified the LI-2017 system as ECCN 5A980. You have determined that an export license is required for shipment of the RoboInterceptor to the UK. Are there any license exceptions that would apply? And if so, are there any specific conditions that must be satisfied?

 

Question #2: Your company is a leading manufacturer of anti-friction bearings (AFBs) and tapered roller bearings (TRBs) used in a variety of industry applications. A new aerospace customer in France has ordered the newest model of AFBs launched earlier this year—AFB2017MON. The system is a radial ball bearing system whose tolerances satisfy ISO 492 Tolerance Class 4. Its rings and rolling elements are made from monel, and its measurements are as follows: inner ring bore diameter of 25 mm; outer ring outside diameter 75mm; and, a width of 15 mm. It is classified as ECCN 2A001.a on the Commerce Control List of the Export Administration Regulations. Your company has begun marketing this new system to customers in the U.S. and abroad, and has been securing export licenses from the BIS for its international customers. The French customer urgently needs these bearings, and asked that the shipment be shipped asap. Are there any license exceptions that would apply to this sale and export to France? And if so, are there any specific conditions that must be satisfied?

 

Question #3: Your company manufacturers miniature, battery-powered, stand-alone, temperature and pressure data loggers (Model Mini-DL1971). Your website states that these data loggers “are a major leap forward in terms of size and performance” in that a real-time clock ensures that all data is time and date-stamped, the storage medium is non-volatile solid-state memory that provides maximum data security even if the battery becomes discharged, and its small size allows it to fit almost anywhere. Data retrieval is accomplished by plugging the data logger into an empty UBS port and utilizing the Company’s specially designed software. The software converts the user’s computer into a real-time strip chart recorder. Data can be printed, or exported to text or Microsoft Excel. The Mini-DL1971 is valued at $289. An automotive manufacturer in Taiwan has ordered twelve (12) of these data loggers for its vehicle crash testing program. You have determined that the data loggers are classified as ECCN 3A002.a.6, which provides for:

General purpose “electronic assemblies,” modules and equipment, as follows: a. Digital data recorders having all of the following…a.6.a. A sustained ‘continuous throughput’ of more than 6.4 Gbit/s to disk or solid-state drive memory; and a.6.b. A processor that performs analysis of radio frequency signal data while it is being recorded.

An export license is required for the data loggers to be shipped to Taiwan. Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #4: Your company makes high speed video cameras that can be used to measure events that happen quicker than a normal video can record, such as explosive blast and ballistic testing of structures and vehicles. One such model is the Blast Tamer High Speed Camera, which is a complete high-speed video recording system with a built-in LD screen and easy-to-use operator interface.  The camera is valued at $1499 each. You have determined that the camera is classified as ECCN 6A003 on the Commerce Control List of the Export Administration Regulations. The King Abdul Aziz University in Jeddah, Saudi Arabia, wants to purchase one Blast Tamer High-Speed Camera for use in its engineering program. A license is required to export the camera to Saudi Arabia.  Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #5: Your company manufactures servers for enterprise workloads One such model is the FLASH-N6 which provides full speed encryption, detection and prevention of attacks to critical data in memory, as well as real-time analytics. A customer in Hong Kong has ordered two FLASH-N6 servers. You have determined that the server is classified as ECCN 5A002 on the Commerce Control List of the Export Administration Regulations. A license is required for export of the server to Hong Kong. Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #6: Your company manufactures the Falcon Communications Platform, which provides innovative signaling solutions to carrier networks worldwide—specifically end-to-end signaling across 2G, 3G and 4G Networks. It is a signaling platform that extends signal transfer point (STP) and signaling gateway (SGW) assets to LTE, M2M and Wi-Fi domains for enhanced connectivity, capacity and revenue. It helps operators manage intelligent routing, screening services, number portability, equipment identity register, and integrated performance/service management from the same database technology and footprint. As they build out the LTE portions of their networks, operators gain seamless connections to PSTN SS7/TDM transports. A customer in Thailand would like to purchase the Falcon Communications Platform. You have determined that the server is classified as ECCN 5A002. A license is required for export of the platform to Thailand. Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #7: Your company manufactures an epitaxial CVD system (Prometheus-2000) which is a semiconductor film deposition system for performing crystal growth by the epitaxial growth method. You have determined that this system is classified as ECCN 3B001 under the Commerce Control List of the Export Administration Regulations. A customer in Brazil has just ordered one of these systems, and an export license is required for the shipment to Brazil. Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #8: You are a professor at an Ivy League academic institution in the area of artificial intelligence. Your current research projects include a program for the development of AI technology that can be used in training systems for commercial pilots. With respect to that project, you have a meeting scheduled in Colorado next month to meet with American Airlines’ program managers to discuss your team’s progress to date. Two days later, you will be speaking at the upcoming AAAI Conference on Artificial Intelligence in China. You plan to take your university-issued laptop with you and fly directly from Colorado to China for your use while on travel. Assume that your laptop contains technology and technical data that is controlled for export to China.  Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?

 

Question #9: Same facts as above, except that you also want to take your personal iPhone and tablet with you to China, which will allow you to access your university emails and view attachments. You want to make sure that you stay in close touch with your research teams back at home.  Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?   

 

Question #10: Your company manufactures sugar cane mill processing equipment such as pumps, valves, parts and components. About five years ago, you sold and exported a sulfuric acid handling system to a sugar cane mill in the Philippines—these systems are used to decompose the sugar cane bagasse for Furfural production (i.e., an industrial chemical made from recycled agricultural materials). The system was exported under a license from the BIS.  The mill just contacted your customer service department to report that the system is no longer functioning, and that it appears that one of the plug valves in the system needs to be replaced. The valves are non-lubricated plug valves, consisting of a body and plug, that are installed on the system. However, about two years ago, your company upgraded the plug valves that it manufacturers and markets, and no longer sells the type of plug valve that was exported with the original equipment to the mill in the Philippines. Specifically, the new plug valve is so efficient that it increases the overall flow rate of the pump but still falls within the tolerance design flow range of the original pump that was exported five years ago. You propose to ship a new plug valve to the mill, and have determined that it is classified as ECCN 2B350.g under the Commerce Control List of the Export Administration Regulations. The plug valve requires a license for export to the Philippines. Are there any license exceptions available? And if so, are there any specific conditions that must be satisfied?   

 

 

Webinar Details:

Part 1: October 17, 2017  1:00-2:30 PM EDT

Part 2: October 26, 2017  1:00-2:30 PM EDT

Length: 1 hour 30 minutes (Each webinar comprised of 1 hour of commentary and 30 minute Q&A session)

Cost: $295 per person (additional employees from the same company $100 each)


Register Now **Contact us for special payment arrangements.

Each registrant will receive copies of the presentations, a certificate of completion, and access to both of the webinar recordings.