Export Compliance

Questions and answers about Export Compliance

  • Issues with exporting to a ship?

    Question: A customer wishes to install software that we wrote/license on ships. The ships are registered in Germany but can travel almost anywhere. Are there special export rules related to exports destined for ships, aircraft or other methods of transport? Some software is EAR99 but some are 5A002 but qualify for license exception ENC. The […]

  • Exporting Finished Goods that’s comprised of consigned Raw Materials

    Question: Hello! – If a US manufacturer (USPPI) sells to a foreign buyer (FPPI) for finished goods which contains consigned materials sent to them earlier from that foreign buyer, is it presumed that the sales price from the US manufacturer to the foreign buyer should be excluding the value of the consigned materials that were […]

  • Export Compliance Audit Form

    Question: Hi, does anyone have an export control audit form you are willing to share? I am going to audit my logistics team and would like to use the forum as a template. Asked by: Alex Greene – agreene@rti.org Answer 1: This is what we use: https://www.icpainc.org/wp-content/uploads/2023/01/Export-Review-Checklist.xlsx

  • Export Classification Correction

    Question: I took over trade compliance for my company in the second quarter of 2022 because of a corrective action in our prior disclosure. Because of the prior disclosure the majority of my focus has been on the import side of trade compliance. As the new year approaches, I am beginning to work on export […]

  • Export Technology Control Plan

    Question: Does anyone have an Export Technology Control Plan or an outline they would be willing to share? Answer 1: Here are some basic requirements of ETCP. https://www.icpainc.org/wp-content/uploads/2022/12/Technology-Control-Plans.doc Answered by: George Tuttle – geo@tuttlelaw.comCompany: Tuttle Law Offices

  • Electronic Integrators and End Use/User Definition Question

    Question: Hello, I have a question to the community regarding foreign integrators and End Use/End User definition. In reviewing the EAR definition of “end-user” and previous ICPA database answers, it was not definitive if it would consider the foreign integrator as  an “end-user” in below scenario of Item A? Scenario: Item A shipped from US […]

  • Controlled software stored and shared in cloud applications

    Question: I am looking for guidance on how firms that develop ,share ,and store software “subject to the EAR” maintain compliance, particularly in cloud applications. The EAR 734. 18 (5) exclusion provides for electronic transmission of controlled tech and software that is not considered an export if it meets the “end to end” encryption standards […]


    QUESTION: How would someone report another company’s export violation? Example: a logistics company is asked to ship something to UAE but mark it as final destination Syria, so it is clear that the intention is the evade the sanctions on Syria. How would they report that to OFAC? ======================================================== Contact your regional OEE (Office of […]


    QUESTION: Interested in what specific KPI reporting industry measures for their exports.    Things like: How many exports? Where are our exports going? How many shipments require a license? How quickly do we receive approval of licenses? How many exports require an EEI declaration? What part numbers are we exporting frequently? Any suggestions would be […]


    Your Social Security Statement QUESTION: We are a large automotive company with mostly EAR99 goods. We are proposing to have a basic online 15-20min export compliance awareness training for all employees. We are getting some pushback on requiring all employees to take this course. Are other companies requiring awareness training for all employees?   If […]

  • Shipping personal items to Germany from the US

    QUESTION: Looking for guidance from the membership.  My company is sending an ex-pat to Germany and their personal items need to ship.  Total value of the shipment is about $350 USD. What is the best way to get these items past German customs? Items are keyboards, office supplies and disinfectants. ========== Answer Each customs agency […]


    QUESTION: My company is a distributor, with a majority of sales activities occurring to resellers. Sometimes in the course of a domestic sale, the reseller would prefer that we ship their purchased goods directly to their foreign customer. Further, we generally have very competitive rates with our carriers, better rates than most of our domestic buyers may […]