This practitioner-level training course gives learners in the UK the foundation for conducting and/or validating U.S. jurisdiction and classification assessments of U.S.-origin items by analysing the critical factors to be considered – which are not always explicit in the regulations -- and the methods for conducting such assessments. The factors include the differences between the philosophies of the ITAR and EAR when reviewing items, analysis of the pivotal definitions to understand when information is export controlled, guidance on the issue of ITAR contamination of non-U.S. items, and tips for reading the control lists. The course also discusses the role effective jurisdiction and classification plays in a company’s compliance programme, including best practices for documenting the determination process. The course presents information, analysis, and commentary that address issues of particular relevance to compliance practitioners operating within the UK.
The broadest objective of this course is to enable learners to recognise the expected steps in conducting a jurisdiction and classification assessment and the factors that impact the result of an assessment. This objective is satisfied when they can:
- Understand the different philosophies regarding the control of technical information under the ITAR and the EAR.
- Recall when the different regulatory terms are applicable.
- Identify technical information that may be export controlled and review for classification.
- Remember that U.S.-origin technical information can contaminate a non-U.S. product or information.
- Understand the requirements for marking technical information as export controlled.
- Recognise when a jurisdiction and classification assessment needs to be updated or reassessed.
- Know that documenting the decision-making process and rationale is critical to successful compliance.
- Understand that they may be responsible for conducting or validating jurisdiction and classification assessments.
- Recognise that they may be asked to assist a vendor in conducting a jurisdiction and classification assessment.
- Understand that they may be responsible for ensuring the appropriate recordkeeping is maintained for a jurisdiction and classification assessment.
Introduction to U.S. Export Classification for Practitioners
- Regulatory Overview
- Layout of the ITAR
- Layout of the EAR
- Jurisdiction and Classification
- Regulated Activities
Jurisdiction and Classification
- Methods of Classification
- Elements of a Commodity (CJ) Request
- Elements of a CCATS Requests
- Encryption CCATS
- Order of Review
- U.S. Munitions List (USML) Review
- USML Category-Specific Scenarios
- Commerce Control List (CCL) Scope and Structure
- CCL Order of Review
- 600 Series
- 9x515 Series
- CCL Entry-Specific Scenarios
- Specially Designed Review
- Other Jurisdiction and Classification Considerations
- Tips, Triggers, and Common Mistakes
- Identification of Technical Data/Technology
- Definition of ITAR Technical Data
- Definition of EAR Technology
- Marking of Technical Data/Technology
- Determining Derivative Data
- Documentation and Reassessment
- Company-Specific Entry
- Key Definitions
- U.S. and Foreign Persons – ITAR
- U.S. and Foreign Persons – EAR
- Defense Article
- Technical Data
- Defense Service
- Internal Activities
- ITAR Authorizations
- EAR Authorizations
- Technical Data Approved for Public Release
- Recordkeeping and Reporting
Trade Compliance Programs
- Identifying and Disclosing Potential Violations
- What Constitutes a Violation Under the ITAR
- Consequences of Noncompliance with the ITAR
- Notification of Potential Violations Within Your Company
- Employees in the UK who are responsible for or involved in conducting and/or validating jurisdiction and classification assessments of U.S.-origin items
- Employees who are responsible for determining if technical information is export controlled by the U.S. or marking export-controlled technical data and technology
- These learners could include engineers, due to the technical nature of the control lists, but can include employees from other business functions.
Course Duration: Approximately 3 hours
Certificate of Completion: King's College London
You have the choice of making a one-time annual payment of $470.00 or electing to be billed monthly at a rate of $39.00 for 11 months following your initial payment.
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