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Managing Export Control Reform Compliance and Developing Regulations

The Export Control Reform will significantly impact how many companies that are in or operate with aerospace, automotive, defense, information technology, telecommunications, and software industries. The first category of changes within the comprehensive and complex reform will become effective on October 15, 2013, requiring companies to reclassify controlled items and obtain export licenses for these controlled assets. Full implementation of ECR compliance operations will fundamentally change the extent of how defense products, software, technology and services, duel-use items, and other intelligence items controlled by the US government. As this course will take place after the first round, this course will cover addressing roll-out challenges, regulation operations and feedback from the Oct. 15 deadline and discuss want to do now and how to plan for future changes and compliances within the ECR.

Turning 'Theory' into 'Practice'?

In addition to the providing attendees with good grounding theories that underpin this discipline, this course will also provide the latest case study examples of operations compliance and timelines in practice. Course attendees will also be given the opportunity to work through many of the challenges faced by their own organization in developing and implementing an effective strategy to be compliant with ECR requirements and put into practice required internal training, organization and filing required government documentation & licensing.  

Who should attend?

This course is ideal for Export Compliance Specialists, Coordinators and AdministratorsGeneral Counsel, Vice Presidents, Directors, Managers of:  Export Compliance, Export Control, Export Policy, Export Administration, Export Operations, Export Licensing, Global Trade Compliance, International Trade Compliance, Logistics & Supply Chain, Product Development, Business Development, Technology Transfer, Sales, Regulatory / Trade Compliance & Development

Key areas to be covered in the programme and documentation

Overview of the ECR and Timeline Requirements ·Review the current state of ECR affairs and previous regulations- where we are right now and where will be headed to- updates on policy and regulatory changes §USML §Commodity Jurisdiction ·Review the Export Control Initiative and its primary goals §Positive List §Bright Light §Higher walls around fewer circles ·The ECR process and timelines §Proposed Rules Based on Categories §Implementation Period  

 Export Control is Now in Effect- Review and Understand What you Should Now Be Doing ·Understand where to find compliance requirements and current statuses for 180 days implantation requirements ·Review feedback on October 15, 2013 category changes and current challenges now that this initial roll-out is live §Cat. VIII revision §CCL Category 600 §Specially Designed Rule §Defense services Changes ·Review examples of operations changes  

Determining Re-Categorization of ITAR and EAR Controlled Items Under the ECR ·Utilize a decision tree to discover proper plans of operations for implantation, processes and interpretations ·Understanding, Applying Exports and Operating in the Newly created 600 Series List for Export Compliance ·Review and understand new criteria that shift the control of items from the U.S. Munitions Lists (USML) to the Commerce Control List (CLL) ·Review CCL Categorization Application process ·Determine eligibility of newest license exception STA and whether your shipment exceptions ·Analyze which ECR initiatives will affect your business operations and the overall export compliance program ·Prepare internal export compliance programs for impending changes in regulations  

Licensing Operations for New Categorization- Licensing EAR Exceptions, ITAR Exemptions, and “Specifically Designed” ·Registering with the ATF ·Evaluating licensing requirements  

Understanding New Classification Categories and its Impacts on Your Business- Opportunities and Threats ·Category XIX- Gas Turbines & Associated Equipment ·Narrowed aircraft types & related articles ·Revised category VII exceptions ·Definitional changes of “specially designed” commodities and software ·Review category roll-out effective January 6, 2013 on military vehicles, vessels of work, submersible oceanic equipment, etc.Categories 6, 7, 20, and 13 of ITAR. ·Discuss proposed rules to military electronic equipments, how it would affect your operations and current anticipations to final rules ·Proposed rules coverage category 11 & 15 and examples of how it would work ·Utilize a Decision tree ·Determining the final and proposed rules we have out there ·Review your current processes in place and how it aligns to scheduled dates for re-culations compliance- what this should look like and what you will need to do  

Classification and Licensing Exercise oMilitary Electronics oSatellite Parts oCCL 600 Series oITAR Technical Data oCCL Technical Data  

Liability Risks for Violations within the ECR ·How to create proper enforcement to respond to changed government enforcement actions ·What to consider and is effected by new rules ·Misinterpretation risks to be aware of ·Consequences of not following classification rules  

Uncovering the Framework of an Effective Export Management & Compliance Program ·Design strategies to create and implement a compliance program that complies with the letter and spirit of the law ·How much Export Compliance is enough for my company? ·How big should our export compliance organization be? ·What does an upgrade IT structure have to do with export compliance? ·If C-Level commitment and adequate resources are key to effective compliance programs, how can you win both? ·Setting up or re-aligning Internal Controls ·Elements of effective internal controls oAssess risk and have program oversight oCreate processes for a corrective actions  

Change Management & Transition Challenges to Ensure ECR Compliance ·Develop tactical plans for delivery and change management communication ·Training emphasis on high-risk areas ·Increase Internal Understanding of Export Compliance Reform through Strategic Communication & Training ·Creating project ownership and governance structures ·Communications & internal training ·Technology transitions, communications & internal training, creating project ownership and governance structures to various stakeholders: o3rd Party Compliance Changes oManufacturers oExporters oBrokers & Forwarders oStrategic Partners    

 Information about the Trainers:  

Adrienne Braumiller   Adrienne Braumiller is the co-founder of Braumiller Schulz LLP and an innovative force in the international trade law arena. With more than 20 years of experience, she is widely recognized as a leading authority in Customs, import, export, foreign-trade zones, free trade agreements and ITAR compliance.   Adrienne has been involved in every aspect of import and export compliance, from developing compliance programs to conducting audits and assessments, representing clients who are under investigation, preparing and submitting voluntary disclosures, preparing and filing classification requests and licenses, analyzing whether specific transactions should be pursued, providing tailored training on specific import/export topics, addressing penalty assessments, and serving as an expert witness in a number of trade cases.   In addition, Adrienne has made presentations as a distinguished lecturer for such groups as the American Association of Exporters and Importers, the International Compliance Professionals Association, the American Conference Institute, the American Petroleum Institute, and the National Association of Foreign Trade Zones. She is also a frequent speaker at government-sponsored events, such as the Department of Energy’s International Nonproliferation Export Control Program (INECP), which hosts industry/government seminars on strategic trade management in various countries around the world. Adrienne has held numerous leadership roles over the years, including serving as the President of the Organization of Women in International Trade at both the local and national levels. She has also held pivotal roles on various international and Customs law committees within local, state and national bar associations. Currently, she is the firm’s representative to the Association of Trade Compliance Professionals (ATCP), as Braumiller Schulz LLP is the only law firm in the country selected to co-sponsor ATCP’s various activities.   Adrienne received her L.L.M. in International Business Transactions from McGeorge School of Law (Sacramento, California) and earned her J.D. at St. Mary’s University (San Antonio, Texas). She studied international law at the University of Salzburg (Salzburg, Austria) and at the University of Oxford, Queen’s College (Oxford, England). She is licensed to practice before the Supreme Court of Texas; the United States District Court of Texas for the Northern District; the Court of Appeals of the District of Columbia; and the United States Court of International Trade.  

Bruce Leeds Bruce Leeds is an attorney at law and of counsel to Braumiller Schulz PLLC, a Dallas-based law firm. He works from Los Angeles and concentrates on export and import compliance matters.   Previously, Mr. Leeds was a Senior Export/Import Advisor in the corporate Global Trade Controls organization of The Boeing Company. His primary assignments included training, bonds and powers of attorney, Customs disclosures and enforcement issues, and handling export, import and Customs related regulatory and legislative matters. Mr. Leeds assisted with implementation of the Customs-Trade Partnership Against Terrorism (C-TPAT), ACE Portal and Importer Self-Assessment (ISA) programs within Boeing. He also provided technical assistance on US and non-US export and import compliance and supply chain security issues.   During his career in industry Mr. Leeds held export and import compliance positions at Hughes Aircraft Company, Hughes Space and Communications Company, and Boeing Satellite Systems, Inc. He started his career with U.S. Customs in Los Angeles, holding Import Specialist and Team Leader positions at LA/Long Beach Harbor and LAX. In addition to being a US Army veteran, Mr. Leeds holds a B.A. from California State University Los Angeles and a J.D (Cum Laude) from the University of West Los Angeles School of Law. He is a member of the California State Bar Association, holds a Customs Broker license and a Certified Customs Specialist designation. He has taught customs broker courses and other classes for the Foreign Trade Association for 32 years.

Benefits to you

·Review the current state of ECR affairs and previous regulations- where we are right now and where will be headed to- updates on policy and regulatory changes

·Understand the ECR process and timelines

·Review feedback on October 15, 2013 category changes and current challenges now that this initial roll-out is live §Cat. VIII revision §CCL Category 600 §specially designed rule §Defense services changes ·Determine Re-Categorization of ITAR and EAR controlled items under the ECR

·Understand licensing Operations for new categorization- licensing EAR exceptions, ITAR exemptions, and “Specifically Designed”

·Utilize a decision tree in the categorization process ·Develop tactical plans for delivery and change management communication

·Classification and licensing exercise §Military Electronics §Satellite Parts §CCL 600 Series §ITAR Technical Data §CCL Technical Data

Companies already benefiting include:

Duration of Course

2 Days Day Course

Course details

December 4-5, 2013 Chicago, IL

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