Requirements associated with the export of space hardware and software have changed significantly since November 2014, when the revised Munitions List Category XV went into effect under the President’s Export Control Reform Initiative. Many of the controls previously subject to State Department regulations have been moved to the Commerce Department. These changes have generated major concerns for exporters. This course offers a detailed look at legacy and new rules under the U.S. Government’s significantly revised export controls for space systems and related technology. The roles of the Department of State’s Office of Defense Trade Controls and the Department of Commerce’s Bureau of Industry and Security are explained, the International Traffic in Arms Regulations (ITAR) are reviewed in detail, and the export licensing process is outlined. Commodity jurisdiction issues and export compliance requirements are also addressed. Course emphasis is on the impact of Export Control Reform on the exportation of space systems and technology, and on the mechanisms to facilitate the process of obtaining timely export approvals while remaining compliant with U.S. Government regulatory requirements.
Each attendee receives extensive notes and reference materials.
Who Should Attend
Anyone involved in export programs for space systems and related technology. This includes manufacturers, exporters, brokers, consultants, carriers, attorneys and others who support and advise exporters.
What You Will Learn
Details of the process of obtaining timely approval from the U.S. Government to export space systems and related technology. The International Traffic in Arms Regulations and Export Administration Rules. Export compliance requirements. Details of the 2014 President’s Export Control Reform Initiative and its impact on export of satellite technology. Country policies and their impact on licensing determinations. Proper shipping procedures and dealing with U.S. Customs. Commodity jurisdiction issues and export compliance requirements.
- Introduction to Export Licensing of Space Systems and Technology.
Overviews of the Directorate of Defense Trade Controls, Bureau of Industry and Security, ITAR, EAR and export licensing process.
- Preparation of Licenses and Other Requests.
The proper method of completing requests to ensure that they are complete, accurate, and completed in a fashion that will facilitate their processing.
- Practical Licensing Exercise.
An exercise to apply principles learned in Session 2.
Mechanisms for obtaining approval to furnish technical assistance, transfer manufacturing rights or know-how, or establish offshore warehousing and distribution facilities.
- Licensing Exemptions.
The advantages and proper use of licensing exemptions and exceptions.
- Case Review and Country Policies.
The organizations involved in case review, their relationship to the overall process, and the particular concerns they have during the course of their review.
- Working With U.S. Customs and the Defense Security Service.
The roles of U.S. Immigration and Customs Enforcement and the Defense Security Service. How to interact with U.S. Customs to ensure shipments are properly documented and handled.
- Compliance Requirements and Programs.
U.S. Government compliance requirements and concerns, and how to ensure that they are adequately addressed. Violations and penalties.
- Current State of Space Licensing and What Lies Ahead.
Recent developments in licensing of space systems and related technology. Projections for the future.
Mr. Allan Suchinsky is an authority and international advisor on U.S. International Trade in Arms Regulations (ITAR) and the U.S. Department of Commerce’s Export Administration Regulations (EAR). Mr. Suchinsky served as Branch Chief at the U.S. Department of State's Directorate of Defense Trade Controls (DDTC) and now counsels representatives of industry and government on export licensing requirements. He serves as advisor to most of the major U.S. defense contractors on such matters. While at the Department of State, Mr. Suchinsky played an instrumental role in drafting the ITAR statutes, established policies and procedures for case processing and hired and trained many of the licensing officers at DDTC.