Question: How and when does your corporation identify foreign national employees for deemed export concerns? We are trying to work on our deemed export compliance and are experiencing some pushback from our HR department on what we can ask, etc.
Does anyone have a Foreign National Program developed for foreign national visitors and guests that can access company facilities which may have controlled products or controlled technology to ensure that they are adhering to Export Administration Regulations (EAR) controls that prevents inappropriate release or transfer of controlled technology to foreign nationals?
DEEMED EXPORT/EMPLOYEEIDENTIFICATION: I’ve been tasked by our executives to benchmark what companies in the high-tech sector are doing to effectively manage deemed export control requirements. Of particular interest to my company is how to identify foreign national’s in such a way that doesn’t reek of discrimination identifier yet meets the requirements and best practices as […]
We are thinking of hiring an engineer from PRC. He will be working on wireless technology for a duty free /EAR99 product. Do I need an export license for him or just an internal technology control plan?
QUESTION ON EXPORT LICENSE (DEEMEDEXPORTS): Our company is finally developing a product controlled for nuclear nonproliferation (NP). I’m hearing conflicting information about whether we need to get export licenses for foreign nationals. The argument against is that the product is not controlled until it is actually built. The argument for is that the definition of […]
I’m a little confused on deemed exports. OK, I’m a LOT confused!! I have a foreign national who is coming to work for us (electronics company). He does not need a license but I want to have a technology control plan in place for him. Another guy in our company says you only do a […]
Does anyone have a form they use when asking for a part description? Suggestions? We set up invoices for engineers and sometimes the descriptions they give are not adequate enough to find the HTSUS & ECCN. We deal in the Semiconductor industry but also ship equipment and various other things needed for manufacturing… We need […]
Does anyone have any experience implementing a deemed export program? We are starting a program and are not quite sure how to ask all of the current employees(U.S. and Foreign Nationals) from a HR standpoint to supply all of the information we need. Any suggestions would be greatly appreciated.
As a follow up to the Foreign National question: Does the government screen foreign nationals before supplying them a Visa? I’d assume that if our product was anything other than EAR99 that we might have to do additional checking based on the country chart. But would the fact that they are allowed a Visa give […]
Can anyone in the membership provide a sample of a Technology Control Plan (TCP) they have submitted to BIS in order to support a deemed export license? The TCP is usually listed as one of the conditions that must be satisfied when the deemed export license is issued to the applicant company. I am familiar […]
We are clamping down on access to ‘controlled technology’ for deemed export purposes. Our controlled technology is only available in two databases, both of which require user names and passwords to access. The level of technology is AT so we are only concerned with persons whose latest country of citizenship or permanent residence is of […]
