All of you logistics officers that are frantically shipping technology to the ends of the earth should realize one thing – the U.S. Bureau of Industry and Security owns you! You may not know who these bad boys are and if you don’t you better start making a list for your in-house counsel for their Voluntary Self-Disclosure submission. If you do, then you know that this happy-go-lucky lot has a say in whether or not the email you just sent your coworker in Sudan was a violation of US federal law. The BIS regulates absolutely every single export that leaves the country and while there are a few exceptions there is not a lot that they don’t get involved in. Thankfully, they are the nicest bunch of folks you’ll ever meet and while their conferences are not smokin’ hot fun you can win a coffee mug.
The BIS has it’s own automated system for assigning Export Control Classification Numbers (ECCN) to the commodity you are shipping – SNAP-R. SNAP-R stand for ‘Simplified Network Application Process Redesign’ and it this attempt to make exporting easier. Luckily, most vendors provide a list of ECCN’s for their products. Here is Apple’s Export Compliance Product/Country Matrix. Once you have your ECCN you can run it through eCustoms Visual Compliance software which will identify export regulations that apply to your product. Keep a copy of the process to show due diligence for audit purposes and in the event the BIS comes knocking.
Read up on the latest export law over at ExportLawBlog.com or get your basics with the BIS’ Introduction to Commerce Department Export Controls. Or, hustle on down to the nearest training and enjoy the look of terror in people’s faces when they realize that they have violated some section of the massive Export Administration Regulations (EAR). Whatever you do, don’t mess with the BIS.
(By the way, your laptop loaded with encryption and wireless technology is one of most heavily regulated items out there. Think twice before heading off to the Sudan or Cuba with it in tow.)
