d3 –ear export exercises 12a white tab exercis… · d3 export scenarios. 2 afas company’s...

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Society for International Affairs

D3 – EAR Export Exercises

D3 Export Scenarios

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AFAS Company’s Tactical UAVExport Management Team

Unmanned Aerial Vehicles for all your Tactical Needs!

Export Scenarios

•Your job: Determine the most effective, efficient manner to execute the export requirements.

• Work together with your table• Ask Questions

•Tools required• ITAR • EAR Table of Contents• EAR Supplement No. 1 to Part 774 CCL (Category 9) from tab 5

• EAR Supplement No. 1 to Part 738 (Country Chart)• EAR Part 740 Exceptions excerpt (740.2; 740.9 - 740.11; 740.13; 740.20)• EAR Supplement No. 1 to Part 740 (Exception Country Groups)

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Export Scenarios

Carmella 500 Propeller

Carmella 500 Launcher

Ground Fueling Station

Carmella 500 Launch RailMicro-SAR Radar

Carmella 500 Tactical UAV

Composite Tail Section

Scenario #1Carmella 500 Engine Propeller

•The Carmella 500 Propellers are requiring field replacement at a rate three times the projected rate due to environmental conditions. The company has identified two test facilities to evaluate why the propellers are failing so quickly. We would like to send each facility two propellers to use in test. The propellers will be destroyed during the test.

• We do not need to send the test facility any technical data/technology on the propellers.

•One facility is located in Japan and the other is located in Singapore.

•Additional Information:• Carmella 500 : USML CAT VIII(a)(5)• Carmella 500 Propellers: (Value: $8,543 each)

•How can we send the propellers?

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Scenario #1Carmella 500 Engine Propeller

•What is the Classification of the propeller? •What are the Reasons for Control?•Is there an authorization required to export to Japan?•Is there an authorization required to export to Singapore?

9A610 Military Aircraft And Related Commodities

9A610 Military aircraft and related commodities. License Requirements

License Exceptions LVS: $1500 GBS: N/A CIV: N/A STA: (1) Paragraph (c)(1) of License Exception STA (§ 740.20(c)(1) of the EAR) may not be used for any item in 9A610.a (i.e., “end

item” military aircraft), unless determined by BIS to be eligible for License Exception STA in accordance with § 740.20(g) (License Exception STA eligibility requests for “600 series” end items).

(2) Paragraph (c)(2) of License Exception STA (§ 740.20(c)(2) of the EAR) may not be used for any item in 9A610.

What are the reasons for Control?

9A610.y.25Reason for Control: NS, RS, MT, AT, UN Country Chart (See Supp.

1 to part 738)

NS applies to entire entry except: 9A610.b; parts and components controlled in 9A610.x if being exported or reexported for use in an aircraft controlled in 9A610.b; and 9A610.y

NS Column 1

RS applies to entire entry except: 9A610.b; parts and components controlled in 9A610.x if being exported or reexported for use in an aircraft controlled in 9A610.b; and 9A610.y

RS Column 1

MT applies to 9A610.t, .u, .v, and .w MT Column 1

AT applies to entire entry AT Column 1

UN applies to entire entry except 9A610.y See § 746.1(b) UN controls

Countries subject to UN Security Council Arms Embargoes are: Central African Republic, Cote d'Ivoire (Ivory Coast), Democratic Republic of the Congo, Eritrea, Iran, Iraq, Lebanon, Liberia, Libya, North Korea, Somalia, and Sudan.

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Reason for Control

9Is there an authorization required to export to Japan?

Reason for Control

10Is there an authorization required to export to Singapore?

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Scenario #1 AnswerCarmella 500 Engine Propeller

• What is the Classification of the propeller? • What are the reasons for Control? • Is there an authorization required to export to Japan?

• Is there an authorization required to export to Singapore?

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Scenario #2Carmella 500 Launcher Rail

• Our sale and delivery of the Carmella 500 TUAV to the ADoD was a success. The ADoD has now decided that in order to best prepare for contingencies, they would like a minimum of five Launcher Rails on-hand at all times in case any might fail. The five rails will be obtained by T3 as part of their contract with the ADoD to provide sustainment

• T3 is an Australian Company; • Additional Information:

• Carmella 500 : USML CAT VIII(a)(5)• Carmella 500 Launcher: 9A610.x• Carmella 500 Launch Rail: (Value: $2,575 each)

• How can we send the rails?

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• What is the Classification of the Launch Rail? • What are the reasons for control?• Is there an authorization required to export to Australia?• What if any exceptions are available to support this export to Australia?STA LVS GOV TMP RPL TSU







9A610.xReason for Control: NS, RS, MT, AT, UN Country Chart (See Supp.

1 to part 738)


NS Column 1


RS Column 1





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Reason for Control

Is there an authorization required to export to Australia?


• What is the Classification of the Launch Rail? 9A610.x• What if any exceptions are available to support this export to Australia?STA LVS GOV TMP RPL TSU

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� STA Country Group A:5:

�STA Country Group A:6:

License Exception STACountry Groups A:5 and A:6

Argentina Australia Austria BelgiumBulgaria Canada Croatia Czech RepublicDenmark Estonia Finland FranceGermany Greece Hungary IcelandIreland Italy Japan LatviaLithuania Luxembourg Netherlands New ZealandNorway Poland Portugal RomaniaSlovakia Slovenia South Korea SpainSweden Switzerland Turkey United Kingdom

Albania Hong Kong India IsraelMalta Singapore S. Africa TaiwanUkraine

Scenario #2 AnswerCarmella 500 Launcher Rail

• What is the Classification of the Launch rail? • What are the reasons for Control? • Is there an authorization required to export to Australia? • What if any exceptions are available to support this export to Australia?STA LVS GOV TMP RPL TSU

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• The U.S. Government has deployed the Carmella 500 in Afghanistan. The program manager has just phoned with an urgent request received from the field engineers for a Composite Tail Section to replace one where a structural crack was noticed during routine maintenance. They are returning the failed Composite Tail Section to the U.S., but now only have five operational UAVs supporting the U.S. Government, which is the minimum our contract allows at all times.

• Additional Information:

• Carmella 500 : USML CAT VIII(a)(5)• Tail Section : (Value: $10,846)

• What license exception (s) can be used to expedite delivery to BagramAirfield?

Scenario #3Carmella 500 Composite Tail Section


• What is the Classification of the Composite Tail Section? • What are the reasons for control?• Is there an authorization required to export to Afghanistan?• What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

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9A610.tReason for Control: NS, RS, MT, AT, UN Country Chart (See Supp.

1 to part 738)


NS Column 1


RS Column 1





Reason for Control(Supplement 1 to § 738)

Is there an authorization required to export to Afghanistan?

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• What is the Classification of the Composite Tail Section? 9A610.t• What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

Scenario #3 AnswerCarmella 500 Composite Tail Section

• What is the Classification of the Composite Tail Section? • What are the reasons for Control? • Is there an authorization required to export to Afghanistan? • What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

• Would Exception RPL be acceptable? Why or why not?• Would Exception GOV apply?

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• The U.S. Government has deployed the Carmella 500 in Afghanistan. The program manager has just phoned with an urgent request received from the field engineers for a Fueling Station to replace one that has failed in the field. They are returning the failed Fueling Station to the U.S., but now only have two operational Fueling Stations supporting the U.S. Government, and our contract requires three operational Fueling Stations deployed at all times.

• Additional Information:

• Carmella 500 : USML CAT VIII(a)(5)• Fueling Station: (Value: $8,223)

• What license exception (s) can be used to expedite delivery to BagramAirfield?

Scenario #4Carmella 500 Fueling Station

Scenario #4Carmella 500 Fueling Station

• What is the Classification of the Fueling Station? • What are the reasons for control?• Is there an authorization required to export to Afghanistan?• What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

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9A610.fReason for Control: NS, RS, MT, AT, UN Country Chart (See Supp.

1 to part 738)


NS Column 1


RS Column 1





Reason for Control(Supplement 1 to § 738)

Is there an authorization required to export to Afghanistan?

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Scenario #4 Carmella 500 Fueling Station

• What is the Classification of the Fueling Station? 9A610.f• What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

Scenario #4 AnswerCarmella 500 Fueling Station

• What is the Classification of the Fueling Station? • What are the reasons for Control? • Is there an authorization required to export to Afghanistan? • What if any exceptions are available to support this export to Afghanistan?STA LVS GOV TMP RPL TSU

• Would Exception RPL be acceptable? Why or why not? • Would Exception GOV apply? • Which provisions of GOV apply?

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Scenario #5Carmella 500 Launcher

• Our product performance in Afghanistan and Australia has really opened up our marketing activities, and to capitalize on that momentum, we want to send a launcher to the Singapore Trade Show to put on display for all to see.

• The trade show will last for seven days, and we anticipate the launcher being in country for no more that two weeks.

• The launcher will be located in a secure facility and controlled by our AFAS employees who will serve as the ultimate consignee

• Additional Information:• Carmella 500 : USML CAT VIII(a)(5)• Carmella 500 Launcher: 9A610.x• Carmella 500 Launch Rail: (Value: $2,575 each)

• How can we send the launcher?


• What is the Classification of the Launcher? • What are the reasons for control?• Is there an authorization required to export to Singapore?• What if any exceptions are available to support this export to Singapore?STA LVS GOV TMP RPL TSU

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1 to part 738)


NS Column 1


RS Column 1





Reason for Control

Is there an authorization required to export to Singapore?

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• What is the Classification of the Launcher? 9A610.x• What if any exceptions are available to support this export to Australia?STA LVS GOV TMP RPL TSU


• What is the Classification of the Launcher?• What are the reasons for control? • Is there an authorization required to export to Singapore? • What if any exceptions are available to support this export to Singapore?STA LVS GOV TMP RPL TSU

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• Our product performance in Afghanistan and Australia has really opened up our sales activities, and just last month, we completed delivery of the Carmella 500 TUAV to the Singapore MoD. The Singapore MoD, much like Australia has also decided to maintain additional Launcher Rails on-hand at all times as a contingency. The rails will be obtained by Singapore Sling Company, the MoDs in country service provider;

• Additional Information:• Carmella 500 : USML CAT VIII(a)(5)• Carmella 500 Launcher: 9A610.x• Carmella 500 Launch Rail: (Value: $2,575 each)

• How can we send the rails?


• What is the Classification of the Launch Rail? • What are the reasons for control?• Is there an authorization required to export to Singapore?• What if any exceptions are available to support this export to Singapore?STA LVS GOV TMP RPL TSU

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1 to part 738)


NS Column 1


RS Column 1





Reason for Control

Is there an authorization required to export to Singapore?

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• What is the Classification of the Launch Rail? 9A610.x• What if any exceptions are available to support this export to Australia?STA LVS GOV TMP RPL TSU

� STA Country Group A:5:

�STA Country Group A:6:

License Exception STACountry Groups A:5 and A:6

Argentina Australia Austria BelgiumBulgaria Canada Croatia Czech RepublicDenmark Estonia Finland FranceGermany Greece Hungary IcelandIreland Italy Japan LatviaLithuania Luxembourg Netherlands New ZealandNorway Poland Portugal RomaniaSlovakia Slovenia South Korea SpainSweden Switzerland Turkey United Kingdom

Albania Hong Kong India IsraelMalta Singapore S. Africa TaiwanUkraine

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Scenario #5 AnswerCarmella 500 Launcher Rail

• What is the Classification of the Launch Rail? • What are the reasons for control? • Is there an authorization required to export to Singapore? • What if any exceptions are available to support this export to Singapore?STA LVS GOV TMP RPL TSU

Scenario #7Obtain a BIS License

1. What is the BIS Export License form?______________2. What is the Electronic System used for submitting BIS

Applications?________________3. Based on the scenario provided, who would be:

a) The End User:________________b) The Ultimate Consignee: _____________

4. Is a purchase order required to support this license submission?____5. With a contract requirement to maintain 5 Launcher Rails on-hand at

all times and trends indicate the MoD goes through approximately 5 rails per year, how many launch rails should you request? ____

6. Is it possible for a BIS Hardware license to have more than one (1) End User? ______________

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Questions?

d3 –ear export exercises 12a white tab exercis… · d3 export scenarios. 2 afas company’s...

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