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NOAA Workshop on U.S. Export Controls
June 10th & 11th, 2009 – HCHBJuly 21st & 22nd, 2009 - Seattle
June 2009 2
U.S. Department of CommerceBureau of Industry and Security
Deemed Export Compliance
Bernard KritzerDirectorOffice of Exporter [email protected]
June 2009 3
Agenda
• Export Controls Overview• How to Classify Items on the Commerce Control
List• Foreign National Visitor and Guest Access
Program• Deemed Exports Overview• NOAA Deemed Export Compliance Program• Exercises• Show how to navigate and use the EAR
June 2009 4
BIS is here to help!
• Outreach Activities• Exporter Counseling• Advisory Opinions• Commodity Classifications• Compliance Strategies
June 2009 5
Need Assistance?
Bureau of Industry and Security Ph. (202) 482-4811Outreach & Educational Services Fax (202) 482-2927
14th St. & Pennsylvania Ave. NWWashington, DC 20230
Western Regional Offices3300 Irvine Avenue, Suite 345 Ph. (949) 660-0144Newport Beach, CA 92660 Fax (949) 660-9347
96 North 3rd Street, Suite 250 Ph. (408) 291-4212San Jose, CA 95112 Fax (408) 291-4320
June 2009 6
7June 2009
Bureau of Industry and Security
■ Bureau Mission: to advance U.S. national security, foreign policy, and economic interests
Statutory Authority: Export Administration Act (EAA) of 1979, as amended; International Emergency Economic Powers Act, as amended
Responsibilities: BIS is responsible for implementing and enforcing the Export Administration Regulations (EAR), which regulate the export and reexport of most commercial and dual-use items.
8June 2009
The ThreatThe Threat
■ Dangers of illegal technology transfers Dangers of illegal technology transfers
are very real: are very real:
‑ ‑ WMD ProliferationWMD Proliferation
‑ ‑ Weapon Design/ManufactureWeapon Design/Manufacture
‑ ‑ Industrial EspionageIndustrial Espionage
■■ U.S. economy damaged by illegal U.S. economy damaged by illegal
technology transfers.technology transfers.
9June 2009
The ThreatThe Threat■ Significance: Both national security and
U.S. economy can be seriously damaged by illegal technology transfers.
■ Damage to the economy can include loss of large amounts of proprietary R&D done
over many years.
■ Loss of proprietary R&D can result in the establishment and/or enhancement of
foreign competitors in leading edge technology sectors.
10June 2009
Origin of the Threat
■ U.S. Intelligence Community has noted: Collection and acquisition activities from
over 56 foreign nations 13 countries assessed to be most aggressive
collectors of U.S. proprietary economic information and critical technologies
Use of clandestine and illegal methods to collect technology
U.S. private sector studies estimate loss in the billions every year
11June 2009
What is being targeted?
Nationally Biotechnology
Pharmaceuticals
Nanotechnology
Quantum Computing
Advanced Materials
Communications and Encryption Technology
Weapons Systems yet unclassified
12June 2009
Methods Used to Target Technology
Unsolicited emailsUnsolicited emails
Front companiesFront companies
Liaisons with universities Liaisons with universities that have ties to defense that have ties to defense contractorscontractors
Recruitment by foreign Recruitment by foreign intelligence servicesintelligence services
National laboratoriesNational laboratories
Compromise of laptop Compromise of laptop while traveling overseaswhile traveling overseas
Attending/Hosting Attending/Hosting conferencesconferences
Relocating R&D facilities Relocating R&D facilities overseasoverseas
Circumventing export Circumventing export control lawscontrol laws
Visiting scientific and Visiting scientific and research delegationsresearch delegations
HackingHacking
Downloading information Downloading information from your networkfrom your network
13June 2009
Deemed Export Enforcement Facts
■ Since 2004, Export Enforcement has closed over 120 investigations, involving a deemed export. Many of these investigations resulted in action being taken or the issuance of a warning letter.
Since 2004, BIS has issued 19 final orders in 17 investigations involving deemed export violations. This has resulted in over $2 million in fines.
Approximately one-half of the cases involved Voluntary Self- Disclosures (VSDs) and both commodity and technology exports.
Eight cases involved deemed export violations alone.
Most violations involved unauthorized transfers of Category 3 (Electronics) and Category 5 (telecommunications).
14June 2009
Key Compliance Issues Since 2004, a central theme that has been identified in the
course of over 120 investigations of deemed exports has been the poor communications or disconnect between the key compliance actors in the private sector:
1) Export Compliance Personnel
2) Human Resources
3) Hiring Managers There were also issues surrounding foreign visitors and
the need for enhanced compliance training.
This is significant for high technology companies because the investigations identified the fact that many companies maintained effective programs for commodities but that it did not carry over in the area of technology.
15June 2009
Technology Control Plan (TCP)
■ The key to technology export compliance is an effective Technology Control Plan.
■ A TCP should contain the following essential elements:
• Management commitment to export compliance• Physical security plan• Information security plan• Personnel screening procedures• Training and awareness program• Self-evaluation program
■ Meaningful compliance is “win-win” because it protects national security and allows a company to protect its proprietary technical data essential to R&D and bringing new products to market timely.
16June 2009
Key Points for Discussion Successful deemed export compliance
incorporate commodities and technologies.
Successful deemed export compliance also represents management’s commitment to a holistic approach, involving successful interaction between the key stakeholders--export compliance personnel, hiring managers, and human resources.
Rarely have we seen a deemed exporter fail that established and maintained a strong TCP, successful interaction between internal stakeholders, and meaningful annual assessments of its program.
17June 2009
Key Points for Discussion The cost of such compliance is small given
the potential downside loss of millions of dollars of proprietary technology and compromises to national security.
Meaningful deemed export compliance also requires an active partnership between government and all affected stakeholders.
Overview of the Export Administration Regulations
(EAR)
June 2009 19
BIS Mission
• To advance U.S. national security, foreign policy, and economic interests.
– BIS is responsible for implementing and enforcing the Export Administration Regulations (EAR), which regulate the export and reexport of most commercial items.
June 2009 20
How Do We Control Exports?
Statutory Authority
• Export Administration Act (EAA) of 1979, as amended
• International Emergency Economic Powers Act, as amended
June 2009 21
Broad jurisdiction BUT… narrow license requirements
Export Administration Regulations (EAR)
• Implement the Export Administration Act
• Apply to most commercial items
June 2009 22
Where can you find the EAR
• Code of Federal Regulations– 15 CFR 730-774– www.gpoaccess.gov
• Available on-line:– www.bis.doc.gov
• Order from Government Printing Office– 866-512-1800 (toll-free)– www.access.gpo.gov
June 2009 23
Why Do We Control Exports?
• National Security• Foreign Policy
– Anti-terrorism– Crime control– Regional Stability
• Non Proliferation– Nuclear weapons– Chemical/biological weapons– Missiles
June 2009 24
Who Else is Involved in Export Controls?Other Regulatory Agencies
Part 730, Supplement 3
• US Dept. of State - Directorate of Defense Trade Controls
• US Dept. of Treasury - Office of Foreign Assets Control
• US Dept. of Energy
• Nuclear Regulatory Commission
• US Dept. of Commerce – Patent & Trademark Office
• US Department of Interior
• Food and Drug Administration
• U.S. Department of Commerce –records) Bureau of the Census (trade statistics and SEDs/AES
• U.S. Department of Homeland Security – Border and Transportation Security– U.S. Customs Service (works with BIS to ensure compliance)
June 2009 25
Important EAR Terms
• Dual-Use• Item• Export• Reexport• Deemed export/reexport• Commerce Control List (CCL)• Export Control Classification Number (ECCN)
June 2009 26
Dual-use Items
• Items that have both commercial and military or proliferation applications.
• This term is often used informally to describe items that are subject to the EAR.
June 2009 27
What is an item?Part 772
June 2009 28
What is an export?
• An export is a shipment or transmission of items
out of the United States.
June 2009 29
What is a deemed export?
• The release of technology or source code to foreign national in the US is deemed to be an export.
June 2009 30
What is a reexport?
• A reexport is a shipment or transmission of items subject to the EAR from one foreign country to another.
June 2009 31
Technology and Software Exports and Reexports
• Include transfers regardless of the method or media– Consultations– Phone conversations– Instruction– Conferences– Application of knowledge– Visual inspections– Disks, blueprints, hardcopy, etc.– Internet, E-mail, Fax
June 2009 32
Other Important Concepts
• Commerce Control List (“CCL”)
• Export Control Classification Number (“ECCN”)
June 2009 33
What does “Subject to the EAR” mean?§734.2(a)
Items and activities under the regulatory jurisdiction of the EAR– Remember there are other government
agencies that administer export controls
“Subject to EAR” does not mean that a license is automatically required
June 2009 34
What is “Subject to the EAR?”§§734.3-734.5
• Items in the United States
• Some items located outside of the United States
• Activities of U.S. and Foreign Persons
June 2009 35
What is “Subject to the EAR”? Items in the United States
§734.3(a)(1)
• ALL Items in the United States, except: – Publicly available technology & software (excluding
encryption)– Items subject to the exclusive jurisdiction of
another federal department or agency– Literary publications, such as newspapers or
literary works (non-technical in nature)
June 2009 36
What is “Subject to the EAR”? Items Outside the United States
§734.3
• Some items located outside the United States:– U.S.-origin items wherever located– Certain foreign-made items, if:
• The value of the U.S. content exceeds the de minimis percentage
• The foreign-product item is the direct product of U.S. technology or software
June 2009 37
Who is “Subject to the EAR”? U.S. Persons and Foreign Persons
§734.5
• Certain activities of U.S. persons (§744.6)– Related to proliferation
• Activities of U.S. or foreign persons prohibited by any order issued under the EAR.
June 2009 38
Overview-Summary
• BIS regulates exports, reexports and certain transfers of items subject to the EAR in addition to certain activities of U.S. persons.
• Important terms: Items, export, reexport, deemed export, CCL & ECCN
• First order of business is to determine whether or not your transaction is subject to the EAR.
Classification of Items on the Commerce Control List
Darrell SpiresEngineer
Office of Nonproliferation and Technology Transfer Controls
June 2009 40
Topics of Discussion
• Determining the Export Control Classification Number (“ECCN”)– The Commerce Control List (“CCL”)
• Self-Classification
• Official Commodity Classification Request– SNAP-R
June 2009 41
Why are classifications so important?
• Proper classifications prevent:
– Delays in exporting
– Potential violations of the EAR
June 2009 42
Commerce Control List (“CCL”)Part 774, Supplement No. 1
• Contains lists of those items subject to the licensing authority of BIS
• Each entry is called an Export Control Classification Number (“ECCN”)
• Most items are described in terms of their technical parameters
June 2009 43
What does Export Control Classification Number (“ECCN”) tell us?
Part 772
• What items are controlled?
• Why BIS controls the item?
• Which destinations will require a license?
– Country Chart in Supp. 1 to part 738,
• What (if any) list-based license exception applies?
June 2009 44
The Structure of the ECCN
0 A 018
0 Category
A Product Group
018 Type of Control
June 2009 45
Categories of the Commerce Control List
0 Miscellaneous & Nuclear Materials
1Materials, Chemicals, Microorganisms, and Toxins
2 Materials Processing
3 Electronics
4 Computers
5 Part 1-Telecommunication
5 Part 2- I nformation Security
6 Sensors & Lasers
7 Navigation & Avionics
8 Marine
9 Aerospace & Propulsion
0 A 018
June 2009 46
Product Groups of the Commerce Control List
A Systems, Equipment & Components
B Test, I nspection & Production Equipment
C Materials
D Software
E Technology
0 A 018
June 2009 47
Type of Controls Associated with Entry
0 National Security Reasons
1 Missile Technology Reasons
2 Nuclear Nonproliferation Reasons
3 Chemical & Biological Weapons Reasons
9
Anti-terrorism
Crime Control
Regional Stability
Short Supply
UN SanctionsSurreptitious Listening
0 A 018
June 2009 48
Most of the time related items are grouped in series
Equipment, assemblies
and components
Test, inspection
and production equipment
Software
Technology
Materials
June 2009 49
How to Read an ECCN entry
• Number and Heading• License Requirements
– Reasons For Control• License Exceptions (List-based)• List of Items Controlled
– Units– Related Controls– Related Definitions– Items
June 2009 50
How to Read an ECCN
Heading:
ECCN & Descriptio
n
June 2009 51
How to Read an ECCN
License Requirement
s:
Reasons for Control
June 2009 52
How to Read an ECCN
License Exceptions
:
List-Based
June 2009 53
How to Read an ECCN
List of Items
Controlled:
Units
Related Controls
Related Definitions
Items
June 2009 54
June 2009 55
Technology and Software Classification
• Review Commerce Control List (CCL)• Identify Export Control Classification
Number (ECCN)• In most cases, technology tied
directly to hardware “development”, “production”, or “use”
• Refer to General Technology and Software Notes (Supplement No. 2 to Part 774)
June 2009 56
General Technology Note
The export of “technology” that is “required” for the “development”, “production”, or “use” of items on the Commerce Control List is controlled according to the provisions in each category.
June 2009 57
5A101
5D101
5E101
Technology and Software ECCNs
Telemetry Equipment
Telemetry Software
Telemetry Technology
Product Groups D and E
June 2009 58
Technology and Software Terms
• Development
• Production
• Use
• Required
June 2009 59
"Development"• "Development" is related to all
stages prior to serial production, such as: design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into a product, configuration design, integration design, layouts
June 2009 60
"Production"• Means all production stages, such as:
product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance.
June 2009 61
"Use"• Operation, installation (including
on‑site installation), maintenance (checking), repair, overhaul and refurbishing.
June 2009 62
"Required"• As applied to "technology" or
"software", refers to only that portion of "technology" or "software" which is peculiarly responsible for achieving or extending the controlled performance levels, characteristics or functions. Such "required" "technology" or "software" may be shared by different products.
June 2009 63
General Software NoteSupplement No. 2 to Part 774
• Sold from stock at retail selling points without restriction, by means of:
1. Over the counter transactions;2. Mail order transactions;3. Electronic transactions; or4. Telephone call transactions; and
• Designed for installation by the user.
June 2009 64
EAR99 Items• Items that are not specifically listed on the
Commerce Control List yet subject to the EAR, use the designation EAR99 in place of an ECCN.
• This designation may be found at the end of every category of the CCL:
“EAR99 Items subject to the EAR that are notelsewhere specified in this CCL Category or inany other category in the CCL are designated
by the number EAR99.”
June 2009 65
How can you obtain the ECCN of your item?
1. Ask the manufacturer, but verify…
2. Self-classify
• Work with company engineer or someone who knows the item
3. Submit formal classification request to BIS
June 2009 66
An Approach to Self-Classifying Items
• Do an index comparison (good starting point)
You need to understand the functions & characteristics of the item!
June 2009 67
Helpful Hints for Self-Classification
• Get started early classifying your items• Understand organization of CCL and approaches to classifying items• Understand the technical parameters of your item
June 2009 68
How to Request a Classification File using SNAP-R (or BIS-748-P)
• “Best guess” ECCN• Maximum of six items per request• Item details
– Manufacturer– Model/Part number– Applications– Specifications
• Include detailed technical specifications– Pictorial illustration, e.g. sales brochures
June 2009 69
Classification- Summary
Determining an ECCN
1. Check with the Manufacturer
2. Work with company engineer/someone who knows the item
• CCL is organized in a logical manner
• ECCN entries are based on the technical parameters of an item and contain a wealth of information regarding export controls
3. Submit formal classification request to BIS
Determining License Requirements based on ECCN
and Destination
June 2009 71
Commerce Country ChartPart 738, Supplement No. 1
• Reasons for Control/Country Chart• If there is:
– “X” in the box indicates a license requirement– No “X” in the box indicates no license
requirement
June 2009 72
Structure Commerce Country ChartWhen the Destination and the Reason for Control Meet, Ask Yourself…
Is there an “X” in the box?
June 2009 73
No License Required
(“NLR”)
• You may use NLR for:– EAR99 items, or– ECCNs where there is no “X” on the Country Chart
under reason(s) for control; and– When the transaction does not require an export
license based on any other licensing requirement (e.g., end-use/user requirements)
June 2009 74
Summary-Determining Licensing Requirements based on ECCN & Destination
• “X” in the box indicates a license requirement
• No “X” in the box indicates no license requirement
License Exceptions
Toni JacksonExport Administration Specialist
Office of Exporter Services
June 2009 76
There is an “X” in the Box…
What do I do?
June 2009 77
Topics of Discussion
• What is a License Exception?
• Restrictions
• List Based License Exceptions
June 2009 78
What is a License Exception?Part 740
An authorization that allows you to export or reexport, under stated conditions, items subject to the EAR that would otherwise require a license.
June 2009 79
When can’t you use a License Exception?
§740.2• Authorization has been suspended or revoked• Export subject to a General Prohibition that is
not eligible for License Exceptions.• Surreptitious Interception Devices • Crime control items to most destinations• Most Missile Technology control items• Embargoed destinations, in most instances
For Full list Refer to §740.2
June 2009 80
The way the EAR sees the world…
Country Groups Supplement 1 to Part 740
Group A: Regime Members
Group B: Less Restricted
Group D: Countries of Concern
Group E: Terrorist Supporting
June 2009 81
Commerce Control List-Based License Exceptions
Availability Based on ECCN– Shipments to B Countries (GBS)– Civil End Users (CIV)– Limited Value Shipments (LVS)– Technology and Software Restricted
(TSR)– Computers (APP)
June 2009 82
GBS Group B Shipments §740.4
• Shipments to Country Group B• Commodities requiring a license to the
ultimate destination for national security reasons only
June 2009 83
CIV Civil End-Users §740.5
• Country Group D:1, except North Korea
• Items that require a license to the ultimate destination for national security reasons only
• Civil end-uses and end-users– No military or proliferation
end-users/uses
June 2009 84
LVS Limited Value Shipment §740.3
• Country Group B• Commodities• Net value cannot exceed LVS value limit• Annual value restriction
– 12 x LVS value of same ECCN to same consignee
• Single shipment
NO splitting orders!
June 2009 85
TSR Technology & Software Under Restriction
§740.6
• Country Group B
• Technology & software requiring a license to the ultimate destination for national security reasons only
• Prior to use, written assurance required from consignee
June 2009 86
TSR Written Assurance
• Letter, other written communication, licensing agreement, fax
• No written assurance -- No TSR
June 2009 87
Summary-License Exceptions
• Make sure your deemed export requires a license (i.e. there is an “X” in the box), before reviewing the License Exceptions.
• Before going to a specific license exception, make sure there are no restrictions.
• Each exception is unique, make sure you meet of all of the criteria.
William ArvinSenior Export Policy AnalystOffice of Exporter Services
Deemed Exports
June 2009 89
Deemed Exports: Definition
• Release of • technology or source code • that is subject to the EAR • to a foreign national • in the United States (EAR
§ 734.2(b)(2)(ii)).
• Release is “deemed” to be an export to foreign national’s home country
June 2009 90
Technology or Source Code Possible Release Methods
• Tours of laboratories
• Research, development, & manufacturing activities
• Foreign students or scholars conducting research
• Hosting a foreign scientist
June 2009 91
Deemed Export Rule Does Not Apply To:
• United States Citizens;• Permanent Resident Aliens (i.e., “Green Card” holders); and• Protected individuals under 8 U.S.C.
1324b(a)(3). Protected individuals include political refugees and political asylum holders.
June 2009 92
Country of Origin(Permanent Residency)
Release of technology to a foreign national of one country, say India, who has obtained permanent residency in another, say the U.K., is treated as if the technology transfer were being made to the U.K. and licensing requirements would be the same as for a British national in the U.K.
If the Indian national becomes a British citizen, transfers of technology would be viewed as transfers to the U.K.
June 2009 93
If an Indian foreign national becomes a citizen of the U.K. but retains Indian citizenship, the most recent citizenship is with the U.K. and releases of technology would be viewed as releases to the U.K.
As a general principle, a foreign national’s most recently obtained citizenship governs the licensing requirement.
Country of Origin(Dual Citizenship)
June 2009 94
Deemed ExportsLicense Requirements
• Is the technology (or source code) subject the EAR?
• Is a license required?
June 2009 95
Technology Not Subject to the EAR
• Publicly available (EAR § 734.7)• Generally accessible to the interested
public• Periodicals, books, print, electronic
other media forms• Libraries (university, public etc)• Released at open conferences
June 2009 96
Technology Not Subject to the EAR
•Product of fundamental research (EAR § 734.8)•Basic and applied research where resulting information is ordinarily published and broadly shared within scientific community
June 2009 97
Technology Not Subject to the EAR
• Educational information (EAR § 734.9)• Released by instruction in catalog courses• Associated teaching laboratories of academic
institutions
• Patent information (EAR § 734.10)• Public information available on patent
application
June 2009 98
Technology Not Subject to the EAR (Cont.)
• Technology subject to the exclusive export licensing jurisdiction of another agency• Directorate of Defense Trade
Controls• Nuclear Regulatory Commission• Department of Energy
June 2009 99
Deemed Export License Requirements
• Usually Commerce Control List Based• Other license requirements based on
• End use• Embargoed destinations• Entity List
June 2009 100
Deemed Export License Requirements
• Classify the commodity • Second character of ECCN will be A, B or C
• Look for a related software (D) or technology (E) ECCN usually in the same category
• Most software and technology ECCNs apply to software or technology for “development,” “production,” or “use.”
June 2009 101
Deemed Export License Requirements
• “Development” – all stages prior to serial production
• “Production” – all production stages including inspecting and testing
• “Use” – Operation, installation, maintenance, repair, overhaul and refurbishing• E.g., Providing operating instruction for a
machine by itself is not a transfer of use technology for that machine
June 2009 102
Deemed Export License Requirements
• Determine the classification of the technology or software
• Identify reasons for control• Determine foreign national’s home
country• Check country chart to see if a
license is required to that country.
June 2009 103
The Deemed Export Application
• Detailed letter of explanation• Comprehensive resume• Complete job description• Foreign national’s particular
qualifications• Safeguards to restrict access to that
approved (Technology Control Plan)
June 2009 104
Letter of Explanation• Identities of all parties to the transaction• Exact project location (where the technology or
software will be used)• Type of technology and scope• Availability abroad of comparable foreign
technology or software• Form in which the technology will be released
and the uses for which the technology will be employed.
• Applicant’s internal technology control plan
June 2009 105
Foreign National’s Resume
• Include all educational institutions attended beyond high school
• Street addresses
• Degrees or certificates received.
• All positions held
• Employers’ names and street addresses
• Brief description of work done.
June 2009 106
Foreign National’s Resume (Cont.)
• Account for all time since from high school graduation
• Present in month and year format
• No gaps greater than 30 consecutive days.
• Include brief abstracts of all scientific and technical papers published, and presentations at scientific and technical conferences.
June 2009 107
Technology Control Plan
• The requirement for a technology control plans are a standard condition found in deemed export and technology exports licenses.
June 2009 108
Technology Control Plan (Cont)• Essential elements:
• Physical security plan• Information security plan• Personnel screening procedures• Training and awareness program • Self evaluation program• Corporate commitment to export
compliance
June 2009 109
Helpful Information
• Does the foreign national:• Have strong ties to the U.S. (e.g., family
here, home ownership, etc.) and / or • Intend to become a U.S. citizen?
• What ties does the foreign national have to his / her country of origin?
• What special benefits or expertise the foreign national brings to the applicant?
June 2009 110
BIS - Application Review• Verify classification of technology• Review licensing requirements & license
exceptions based on home country• Assess appropriateness of job description,
responsibility, title • Assess appropriateness of education level
and field to technology & end-use • Determine reasons for control for correct
referrals
June 2009 111
License Exceptions for Deemed Exports
• CIV: Civil End Use (EAR § 740.5)• ECCN 3E002 technology.
• APP: Adjusted Peak Performance (EAR § 740.7)
• ECCNs 4D001 and 4E001 software and technology
• Both require foreign national review
June 2009 112
Foreign National Review (FNR)Sections 740.5 & 740.7
• Applicant must submit FNR request before disclosing technology under license exceptions CIV and APP.
• Request must provide same information on the foreign national as a license application.
• Faster review than license applications
June 2009 113
License Exceptions for Deemed Exports
• TSR: Technology and Software Under Restriction (EAR § 740.6)• Applies to technology and
software under national security only for country group “B” nationals.
• Letter of assurance required
June 2009 114
Deemed Export Application Statistics FY2008-- Results
• Total applications processed1252• Approvals 1147 (91%)• RWA’s 101 (8%)• Denials 4 (>1%)
June 2009 115
Deemed Export Application Statistics FY2008– Nationalities
• 57% People’s Republic of China• 10% India• 7% Russia• 6% Iran• 5% United Kingdom• 1% Germany• 2% Others
June 2009 116
Deemed Export Contacts
Deemed Exports and Electronics Division
Brian Baker Kurt FranzDirector Senior Export Policy
Analyst202-482-5534 [email protected] [email protected]
Bob JusteSenior Electrical [email protected]
