The "New Normal": Understanding & Implementing Export Control Reform

The past year has witnessed dramatic changes for many exporters under the federal Export Control Reform (ECR) Initiative.  Items under twelve different U.S. Munitions List (USML) categories have migrated from State to Commerce Department jurisdiction, with the most recent changes affecting categories for electronics and satellite technology.  While most exporters impacted by the reforms will experience a lesser degree of control, they will also experience a possibly painful transition and a decidedly greater degree of complexity in their export compliance operations.  Moreover, key definitions and provisions introduced as part of the reform initiative will impact all exporters of controlled items - not just those exporters undergoing jurisdictional changes.  This seminar will take an in-depth look at the ECR initiative, including:  the scope of the reforms; implementation schedule; product groups affected; USML and Commerce Control List (CCL) structural changes; impact on commodity jurisdiction, classification and licensing; newly-standardized definitions such as “specially designed,” “technical data,” and “technology”; use of license exceptions, such as STA, and di minimis provisions; applicability of the ITAR see-through rule; and more.  The seminar will also feature presentations by two exporting firms impacted by Export Control Reform to share their insights and best practices for implementation and compliance.