Ask Yourself What, Where and To Whom

"Increasing attention is being directed toward export compliance, both from the federal government and from private industry. Companies have become painfully aware of the dire consequences that attend an export compliance misstep--like an unpleasant encounter with an investigator or a prosecutor. Some companies and organizations have had robust export compliance systems in place for years; others are scrambling to put a rudimentary system in place. This export compliance white paper is intended to offer some general guidelines to private companies and other organizations as they undertake export compliance efforts..."

The Second Step is to Ask Yourself "Where am I Exporting?"

"If you are exporting your product, technology, or service (collectively referred to as an "item") and you have determined that your item is on the United States Munitions List "USML," then the analysis is fairly simple. You cannot export a USML item outside of the United States without a license or a license exception. This is true even with simple items, as long as they are on the USML and fall under the jurisdiction of the State Department..."

Export Compliance: Don't Forget to ask '"To Whom?"'

'After you have made a proper jurisdictional determination and classification analysis so that you know "what" you are exporting, and after you have determined "where" you are exporting, you must then determine "to Whom."
WHO IS THE END USER? PROHIBITED PERSONS AND ENTITIES. Even if a license is not required for an item that is being exported, there are still certain parties to whom any export transaction is prohibited. Certain individuals and organizations are prohibited from receiving U.S. exports either due to previous export violations or because of involvement in the proliferation of...'