EXPORT Compliance Audits & Reviews
STTAS export compliance services include compliance audits, process and transaction reviews, comprehensive risk assessments and gap analyses of best practices along with recommendations. Through these in-depth assessments, STTAS makes recommendations to enable clients to improve process planning. Our export compliance assessments are specifically tailored to provide a benchmark from which the company may gauge its level of compliance.
Training
STTAS conducts intensive training workshops for the public at-large, as well as in-house seminars for designated key personnel whose activities are subject to export laws and regulations. STTAS’ seminars focus on the general requirements for exports, re-exports, deemed export and temporary import/export procedures. The seminars also emphasize the defense articles/services on the U.S. Munitions list (USML) regulated by the DDTC. Additionally the seminars address the export and re-export of dual-use commodities overseen by the BIS and the various programs levied against the so-called embargoed and sanctioned countries and specially designated individuals administered by OFAC. STTAS can conduct in-depth training for new and existing personnel on export licensing and control requirements, develop a training syllabus for internal use and provide training to remote installations or foreign-controlled entities. We can also create Web-based e-learning training modules with corresponding testing components for companies that wish to provide outreach to a greater number of employees and automate training initiatives.
Jurisdiction and Commodity Classification Requests
STTAS provides guidance to clients in determining which government agency exercises jurisdiction over the activity or commodity in question. This includes the Bureau of Industry and Security (BIS), the Directorate of Defense Trade Controls (DDTC) and other government agencies. We also prepare and submit requests on behalf of our clients for the proper classification of commodities, technology, software, and technical data.
Licensing Requirement Determinations/Applications
STTAS assists clients in evaluating whether a license is required for proposed transactions based on classification, end-use and/or end-users, and to what extent any license exceptions may be applicable. In addition, STTAS assists clients in obtaining licenses.
STTAS assists clients in assessing the scope of existing licenses and the use of license exceptions. STTAS will also review current recordkeeping procedures to ensure that shipments subject to license or license exception controls are being properly monitored and managed. Further, STTAS assists its clients in establishing an adequate system for tracking the expiration of licenses to ensure proper disposition, renewals or amendments may be timely made.
Export Commodity Classification
STTAS’ experienced professionals and extensive software solutions provide for a robust export classification process. Based on the product/technology, STTAS assists exporters in determining the proper export and tariff classification with appropriate audit trails.
Screening
STTAS works with clients to ensure that all new and potential customers, carriers, freight forwarders, employees and onsite visitors are properly screened against the most current versions of the various restricted parties lists published by U.S. and international government agencies including BIS, DDTC, OFAC, FBI, Interpol, etc.
Managed Services
STTAS provides complete export management services and works with exporters in providing comprehensive export managed services such as classification, screening, order management, license management and freight forwarder management.
ITAR Compliance
STTAS offers assistance in all aspects of ITAR compliance, including the ITAR registration process, determination of licensing requirements and availability of license exemptions and preparation and observation of manufacturing license agreements, technical assistance agreements and distribution agreements.
Re-Export Compliance
A re-export is the shipment of an item from one foreign country to another or the release of technology or software in one foreign country to a national of another. U.S. export laws and regulations control re-exports of U.S. origin items and certain foreign-produced items that incorporate, are bundled with or are commingled with U.S. origin goods, software and/or technology. In many cases a license may be required from the U.S. government to re-export goods or technology to foreign affiliates or foreign end-users. STTAS works with companies in determining re-export licensing requirements and eligible license exceptions or exemptions, as well as filing license applications with appropriate government agencies.
Embargoed and Sanctioned Country Screening
U.S. persons are prohibited from engaging in certain activities with countries that are subject to U.S. embargoes or sanction programs. STTAS assists companies in understanding the various sanction programs and ensuring that potential business activities, imports, exports, re-exports and technology transfers fully comport with such programs.
Encryption
The export and re-export of encryption hardware, software and technology is subject to stringent and complex requirements. STTAS provides advice on the encryption rules under the Export Administration Regulations and can help determine the licensing requirements for encryption products. We can then prepare and submit required encryption review requests and license applications.
Deemed Exports and Technology Transfers
A license may be required before controlled software or technology may be exported from the United States or transferred to a foreign national in the United States. This rule applies not only to foreign nationals working as employees in the United States but also to contractors and those visiting U.S. facilities. STTAS will work with you to identify potential breaches of the deemed export rule and establish adequate safeguards to prevent the unauthorized disclosure of software and technology through a Technology Control Plan. As part of this process, we assist in preparing and submitting any necessary license applications.
Export Compliance for the e-Commerce Industry
Electronic commerce may be subject to U.S. export laws and regulations in the same manner as more traditional transactions. U.S. export laws apply to orders processed via the Internet with tangible delivery of goods, intangible downloads and releases of technology and software, various services performed during transactions, and the transfer of funds to certain entities. STTAS professionals work with e-commerce companies in developing robust export compliance programs tailored to their unique operations, determining licensing requirements and eligible license exceptions or exemptions, and filing license applications with the appropriate government agencies.
Foreign Boycott Reporting
U.S. companies are prohibited from furthering or supporting foreign boycotts that are not sanctioned by the United States. The primary foreign boycott in existence today is the Arab League boycott of Israel. STTAS provides advice and counsel on complying with U.S. anti-boycott requirements, including training personnel to identify foreign boycott requests and the timely filing of reportable boycott requests to the Department of Commerce and the Internal Revenue Service.
Export Management Systems
Developing and implementing a comprehensive export management system that takes into consideration all key aspects and departments is essential, particularly if your operations include overseas locations or numerous types of products or technologies. STTAS has extensive experience in helping companies establish state-of-the-art automated systems that can increase overall efficiencies in addition to export compliance.
Export Due Diligence in Mergers or Acquisitions
Under the principle of successor liability you may be held liable for export violations committed by businesses you acquire. STTAS can offer support and guidance during mergers and acquisitions, ensuring that due diligence investigations include thorough assessments of potential export liability.
Export Professionals
- Anu Gavini
- Brandi Paynes-Bernard
- William Kubitskey
- Holley Russell