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Nigel McCallum Director of Export Operations Samuel Shapiro Company, Inc.

EMCP DEFINED. An Export Management and Compliance Program (EMCP) includes operational policies, procedures, safeguards AND a written set of export-related guidelines that tell employees what is expected of them and provides management with a framework to evaluate whether: What should happen, does happenAnd What shouldn't happen, doesn't happen

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Nigel McCallum Director of Export Operations Samuel Shapiro Company, Inc.

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    3. Who is Watching Exports U.S. Department of State - Directorate of Defense Trade Controls U.S. Department of Justice - Drug Enforcement Administration U.S. Department of Interior - Fish & Wildlife Service U.S. Department of Energy - Nuclear Materials (Not Defense) U.S. Department of the Treasury - Office of Foreign Assets Control U.S. Department of Health and Human Services - Food & Drug Administration U.S. Department of Homeland Security - U.S Customs and Border Protection U.S. Dept. of Commerce - Bureau of Industry & Security - Bureau of Census

    4. Under the Export Administration Regulations (EAR) EAR 730.6, the export control provisions are intended to serve the following: National Security of the United States by restricting the export of certain goods and technology. Foreign Policy of the United States. Short supply interests of the United States by protecting a drain of scarce materials or resources. Nonproliferation by controlling the proliferation (reproduction or spread) of weapons of mass destruction (WMD). International obligations of the United States.

    8. An Effective Compliance Program Can Be A Mitigating Factor With Great Weight !

    9. Dont Let This happen to You Parker Hannifin Corp. Settles Charges Pertaining To Illegal Exports To Taiwan And China (Nov 17, 2005) The U.S. Department of Commerce today announced that Parker Hannifin Corporation of Cleveland, Ohio, has agreed to pay $185,000 in civil penalties to settle charges pertaining to unlicensed exports of fluid control valves to Taiwan and China in violation of the Export Administration Regulations (EAR). The Commerce Departments Bureau of Industry and Security (BIS) charged that, between September 2000 and June 2002, Parker Hannifin committed 53 violations of the EAR. Specifically, BIS charged that Parker Hannifin committed 17 violations by exporting check valves to Taiwan without the required licenses, 17 violations by transferring the check valves to Taiwan with knowledge that violations of the EAR were occurring, one violation by exporting manual stop cock valves to China without the required licenses, and 18 violations by making false statements on Shippers Export Declarations filed with the U.S. Government. Parker Hannifin voluntarily self-disclosed the violations, and cooperated fully in the investigation.

    10. Parties who may have been involved in violations of the EAR are encouraged to submit a Voluntary Self Disclosure (VSD) to BIS Office of Export Enforcement, as provided for in Part 764.5 of the EAR. VSDs are an important indicator of parties intent to bring themselves into compliance with the EAR, and may provide BIS important information on illicit proliferation networks. A VSD is considered a great weight mitigating factor in the settlement of BIS administrative cases.

    11. Dont Let This Happen to You Continued The U.S. Department of Commerce announced that Alcoa Europe, a Swiss company and, indirectly, a wholly owned subsidiary of a domestic company, agreed to pay a $6,000 civil penalty to settle allegations that it violated the antiboycott provisions of the Export Administration Regulations (EAR). The Commerce Departments Bureau of Industry and Security (BIS) charged that, on six occasions, Alcoa failed to report in a timely manner its receipt of a request to refrain from supplying goods or materials manufactured or processed in Israel or using any Israeli organization to handle or transport the items. The transactions involved the sale and transfer of goods from the United States to Dubai, U.A.E. Alcoa voluntarily disclosed the transactions that led to the allegations and fully cooperated with the investigation.

    12. Dont Let This happen to You Continued ITT Corp. agreed to plead guilty to illegally exporting night-vision technology to China and other countries and pay a $100 million fine, one of the largest penalties in a U.S. criminal prosecution, according to the Justice Department.

    16. What is an Effective Export Management And Compliance Program (EMCP)?

    17. An Effective EMCP is a Smart Business Strategy (1) Management, Accountability, and Smart Business Strategies ? Management Commitment and Oversight ? Responsible Personnel and Tasks ? Record Keeping ? Training ? Audits ? Escalation and Notification (2) Streamlining the Up Front Decision Making Process ? Classification and License Determination (3) Compliance Screening ? List Oriented (DPL, Entity, SDN, etc.) ? Diversion Risk Red Flags Check ? End-Use Checks (Proliferation) ? Antiboycott Checks (4) Documenting Compliance Policies and Procedures ? Export Process Narratives and Flow Chart Descriptions

    19. Defining the Parameters of Your Export Program Your Company Profile Your Business Activity Profile Your Customer(s) Profile Destination Country Profiles Your Commodity Profile(s) End-Use Profile Your Order Processing Profile Shipping Profile U.S. Persons Activities Profile

    21. The Management Factor

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