- https://crsreports.congress.gov
- https://uscode.house.gov/
- Bureau of Industry and Security
- Export Administration Regulations (EAR) (doc.gov)
The United States imposes export controls to protect national security interests and promote foreign policy objectives. The Bureau of Industry and Security (BIS) administers and enforces the Export Administration Regulations (EAR) (15 CFR parts 730 – 774), which govern the export, reexport, and transfer (in-country) of items “subject to the EAR” and certain activities of U.S. persons. Items (commodities, software, and technology) “subject to the EAR” include dual-use items and less sensitive military items described on the Commerce Control List (supplement no. 1 to part 774 of the EAR) (CCL) by Export Control Classification Number (ECCN), and items not described in or otherwise classified under any ECCN of any category of the CCL designated as “EAR99.” The EAR is available at https://www.bis.gov/regulations/ear and on the e-CFR (Electronic Code of Federal Regulations).
For assistance with regulatory requirements on items under the export control jurisdiction of other U.S. Government agencies, exporters should consult those U.S. Government agencies. For example, the U.S. Department of State’s Directorate of Defense Trade Controls has authority over critical defense articles and all defense services. A list of other agencies involved in export controls can be found on the BIS website and in Supplement no. 3 to part 730 of the EAR.
BIS works closely with U.S. embassies, foreign governments, industry, and trade associations to ensure that the export, re-export and transfer (in-country) of items subject to the EAR, as well as certain activities of U.S. persons is accomplished in compliance with the EAR.
Guidance and Training:
BIS has published “Know Your Customer” guidance and red flags, to aid exporters in identifying possible violations of the EAR (see Supplement no. 3 to part 732). Dissemination with industry members is highly encouraged to help promote EAR compliance.
BIS offers in-person and virtual training throughout the year on the basics of exporting to more advanced topics. A listing of BIS events is available at https://www.bis.gov/learn-support/training/upcoming-events. BIS also offers online training videos at https://www.bis.gov/learn-support/training-videos. BIS’s Export Control Officers (ECOs) and Export Control Analysts (ECAs) located at U.S. embassies and consulates in 11 overseas locations also conduct outreach to raise awareness of re-export and transfer (in-country) requirements with foreign business communities.
Assistance is available from BIS by contacting an export counselor at (202) 482-4811 (open Monday-Friday, 8:30 am-5:00 pm ET) or by e-mail at ECDOEXS@bis.doc.gov.
Enforcement:
BIS officials conduct site visits, known as End-Use Checks (EUCs), globally with end-users, consignees, and/or other parties related to transactions involving items subject to the EAR and shipped under a license, another form of BIS authorization, or as “no license required.” An EUC is an on-site verification of a non-U.S. party to a transaction, conducted as part of BIS’s licensing process as well as its compliance program, to determine whether the party is a reliable recipient of items subject to the EAR and is in compliance with the EAR and the conditions of a license or other authorization, if applicable. Specifically, an EUC verifies the bona fides of transactions subject to the EAR, including confirming the legitimacy and reliability of the end use and end-user; monitors compliance with license conditions; and ensures items are exported, re-exported or transferred (in-country) in accordance with the EAR. These checks might be completed prior to the export of items pursuant to a BIS export license in the form of a Pre-License Check (PLC) or following an export during a Post-Shipment Verification (PSV), regardless of whether a BIS license is required.
BIS officials rely on EUCs to safeguard items subject to the EAR from diversion to unauthorized end uses/users and destinations. The verification of a foreign party’s reliability facilitates future trade, including during BIS license reviews. If BIS is unable to verify the reliability of the company or is prevented from accomplishing an EUC, the company may receive, for example, more regulatory scrutiny during license application reviews or be designated on BIS’s Unverified List or Entity List, as applicable.
Contact information for BIS’s overseas ECOs can be found at: https://www.bis.gov/about-bis/bis-leadership-and-offices/OEA/export-control-office-program
Consolidated Screening List
The Consolidated Screening List (CSL), available on the International Trade Administration’s Trade.gov website, is a list of parties for which the U.S. Government maintains restrictions on certain exports, re-exports, or transfers of items. The CSL consolidates multiple export screening lists maintained by the Departments of Commerce, State, and the Treasury into a single data feed as an aid to industry in conducting electronic screening of parties to regulated transactions. Exporters should determine the export requirements specific to their proposed transaction by classifying their items prior to export and reviewing the applicable regulations specific to the item(s), the proposed end use and end user, as well as consulting the CSL to determine if any parties to the transaction may be subject to specific license requirements.