Course Summary:
This practitioner-level course examines the authorization types available for reexports of U.S.-regulated hardware, technical information, software, and services received via direct commercial sales. Additionally, this course covers authorization requirements for deemed reexports to dual and third-country nationals, as well as employing U.S. persons at non-U.S. organizations. This course also addresses available authorizations for the temporary return of items to the United States for repair or servicing. The course provides an overview of these areas in relation to the relevant U.S. compliance regimes, including the Export Administration Regulations and the International Traffic in Arms Regulations.
The training provides detailed guidance for implementing the appropriate authorization for transactions that may involve multiple authorization types, as well as identifying when authorizations need to be amended and the process for obtaining these amendments. This course will present information, analysis, and commentary that address issues of particular relevance to compliance practitioners outside the U.S.
Learning Objectives:
The broadest objective of this course is to enable learners to recognize the different types of U.S. authorizations and their applicability to ensure their transaction is compliant. This objective is satisfied when they can:
Trade-Specific Objectives
- Understand the available reexport options based on how U.S.-regulated items were originally received.
- Know the implementation requirements for the different types of authorizations under the ITAR and the EAR.
- Recognize when multiple authorizations are needed for a transaction to be compliant.
- Recall which ITAR exemptions and EAR license exceptions are available for non-U.S. organizations.
- Identify when an authorization is required for employees to have access to U.S.-regulated items.
- Remember that different business functions play a role in authorization management and identifying the need to amend an authorization.
- Distinguish the requirements between permanent and temporary transactions.
Role-Specific Objectives
- Understand that they may be responsible for determining the appropriate authorization for a transaction.
- Recognize that they may be asked to approve the use of a company-certified authorization.
- Realize that they may be responsible for preparing and submitting formal authorization requests.
Target Audience:
- Employees who are responsible for determining licensing requirements for U.S.-origin items and obtaining the appropriate authorization
- Employees who are responsible for utilizing exemptions and exceptions under U.S. regulations
- Employees who are responsible for managing or overseeing trade compliance activities in other business functions such as classification and logistics
Course Outline:
- IntroductionWelcome
An Overview of U.S. Export Authorizations
- ITAR AuthorizationsInitial U.S. Authorizations Under the ITAR
ITAR Authorizations for Reexports and Retransfers
Deemed Reexports Under the ITAR
U.S. Persons Employed Abroad
ITAR Authorizations for Temporary Activities with the U.S.
Part 126 Exemptions
Amending ITAR AuthorizationsNon-U.S. Entity Name or Address Changes Under the ITAR
- EAR AuthorizationsUse of EAR Authorizations by Non-U.S. Persons
General Prohibitions Under the EAR
EAR Licenses
EAR License Exceptions
Deemed Reexports Under the EAR
Amending EAR Authorizations - Department of State Submission PortalDepartment of Commerce Submission Portal
- ConclusionConclusion
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