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KEEPING OUR WORLD UP AND RUNNING Carol Mikula Export Compliance Coordinator Phone: 425 446-5416 carol.mikula@fluke.com Cathleen Bouvart Export Compliance Coordinator Phone: 425 446-6289 c athleen.bouvart@fluke.com. EXPORT COMPLIANCE. EXPORT COMPLIANCE. AGENDA:

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  1. KEEPING OUR WORLD UP AND RUNNING Carol Mikula Export Compliance Coordinator Phone: 425 446-5416 carol.mikula@fluke.com Cathleen Bouvart Export Compliance Coordinator Phone: 425 446-6289 cathleen.bouvart@fluke.com EXPORT COMPLIANCE Export Compliance at Fluke

  2. EXPORT COMPLIANCE AGENDA: • Corporate Compliance Policy Statement • Reasons for Controls • The cost of violations • U.S. Export Control review • What an export transaction is • Questions Export Compliance at Fluke

  3. FLUKE CORPORATE COMPLIANCE POLICY • Adhere strictly to all applicable export control laws and regulations • Train employees • Maintain an internal control program • Disclose known violations CARRY OUT NO TRANSACTION IN VIOLATION OF THE LAW Export Compliance at Fluke

  4. REASONS FORCONTROLS Protect National Security from Military Threats and Acts of Terrorism Promote Foreign Policy Preserve Domestic Availability of Products in Short Supply Prevent Proliferation of Weapons of Mass Destruction Dual-Use products have civilian and military applications

  5. THE COST OF VIOLATION • Civil Penalties in the form of fines • Criminal Penalties resulting in imprisonment • Loss of Export Privileges U.S. Commerce Department along with U.S. Customs and Border Protection, have significantly increased their enforcement of the export regulations Export Compliance at Fluke

  6. EXPORT TRANSACTIONS • Any item that is sent from the United States to a foreign destination is an export. • A deemed export is a “release” of technology, software, or source code to a Foreign National in the United States • Technology is “released” for export • when it is available to a foreign national for visual inspection – example - reading technical specifications • When technology is exchanged orally • When technology is made available by practice or application under the guidance of persons with knowledge of the technology Export Compliance at Fluke

  7. EXPORT TRANSACTIONS • Transfer of Product from U.S • For Sale or No Charge Transactions Shipment or Hand Carry • Temporary Use Demo or Exhibition • Servicing and Repair • Hiring and training of foreign nationals • Training, lectures, seminars • Re-export from original destination Export Compliance at Fluke

  8. U.S. EXPORT CONTROLS • NO Fluke product may be exported or re-exported to: • Cuba, Iran, North Korea, Sudan, or Syria Export Compliance at Fluke

  9. Export Regulations for Fluke’s Thermal Imaging Cameras • The Fluke Thermal Imager is controlled by the Bureau of Industry and Security United States Department of Commerce, diversion of this product contrary to U.S. law prohibited. • An export license must be obtained from the Bureau of Industry and Security, United States Department of Commerce before leaving the United States or Canada. Failure to do so is in violation of the Export Administration Regulations Export Compliance at Fluke

  10. U.S. EXPORT CONTROLS • Denied Persons List (DPL) Violators of U.S. export regulations denied export privileges by the U.S. Government • Specially Designated Nationals (SDN) Parties identified by the U.S. as acting on behalf of embargoed countries Subject to same controls as an embargoed country • ENTITY LIST • Parties identified for known involvement in prohibited end use • U.S. export license required for ALL transactions • Currently includes parties in: Canada, China, Egypt, Germany, Hong Kong, India, Iran, Israel, Kuwait, Lebanon, Malaysia, Pakistan, Russia, Singapore, South Korea, Syria, and the U.A.E. Export Compliance at Fluke

  11. Know Your Customers!!!! • Look for diversion possibilities or “Red Flags” • Customer is evasive or unclear if the shipment is for domestic or foreign use • Unusual ship to location or shipment to a freight forwarder • Product does not match the customers line of business • The customer or purchasing agent is reluctant to offer information about the end-use of the item • The customer is willing to pay cash for a very expensive item • The customer has little or no business background • The customer is unfamiliar with the product's performance characteristics but still wants the product • Routine installation, training, or maintenance services are declined by the customer Export Compliance at Fluke

  12. CONTACTS AND REFERENCES • Fluke contacts for questions regarding regulations on Fluke products are: • Carol Mikula at carol.mikula@fluke.com or phone 425 446-5416, fax 425 446-5778 • Cathleen Bouvart at cathleen.bouvart@fluke.com or phone 425 446-6289, fax 425 446-5778 • Denied parties search: www.visualcompliance.com • You may also refer to www.bis.doc.gov for more details on the US Export Rules and Regulations • Note: Fluke does not endorse Visual Compliance, this is only a recommendation of one of the many services available. Export Compliance at Fluke

  13. SUMMARY • Fluke products are controlled by the U.S. Department of Commerce export laws and regulations • Fluke maintains a strict export compliance program • Violations may result in costly penalties, including loss of export privileges • Watch closely for the “Red Flag” indicators • Know your customers!! • Compliance is the responsibility of everyone • QUESTIONS? Export Compliance at Fluke

  14. EXPORT COMPLIANCE KEEPING OUR WORLD UP AND RUNNING Fluke Export Compliance Team: Carol Mikula 425 446-5416 carol.mikula@fluke.com Cathleen Bouvart 425 446-6289 cathleen.bouvart@fluke.com Export Compliance at Fluke

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