http://www.dunlap-stone.edu/programs/degree-programs/bs-health-care-administration/

V O L U M E 12, I S S U E 7P A G E 3

Understanding the Hidden CostsBy Charlie Mayes, Managing Director, DAV Management

UK Export Week ran from 12-16 November 2012 and was anational series of events designedto inspire and provide practicaladvice for new andexperienced exporters. The‘Week’ as it is known in theexport world is part of acampaign led by Trade andInvestment Minister LordGreen to increase thenumber of British exportersby roughly a quarter. If thisis achieved it is estimatedthat about £36 billion couldbe added to the UK economy.Speaking about Export Week, LordGreen was impressed by the waythat many firms have seized on theexport opportunity since the launchof UK Export Week in 2011.We know that there are £19.5 billionworth of exports generated bycompanies in London and the SouthEast alone and a recent surveyundertaken by workplace solutionprovider Regus found that of theBerkshire firms that don’t currentlytrade overseas, 29% are planning tostart in the next two years. Clearlythere are many benefits to doingbusiness overseas. A recent researchreport unveiled by the UK Trade andInvestment (UKTI) shows thatmany UK firms are increasinglyventuring beyond traditional exportmarkets such as Europe and the USand into high growth markets in Asiaand Latin America.

The UK has always been a greattrading nation and the report showsthat those companies that continuethis tradition by thinking globallystand to reap sizeable rewards. 58%of entrepreneurs said exporting ledto a ‘level of growth not otherwisepossible’. Most economists agreethat the biggest story of the twenty-first century will be a shift in the

economic centre of gravity from thedeveloped world to high-growthmarkets such as China, India, Russiaand Brazil. Companies of all ages and

sizes areincreasinglyf i n d i n gsuccess int h e s emarke t s .The reporta l s ohighlightedthat two infive small

exporters (with less than 10employees) already do business in atleast one high-growth market. Manyinternationalized firms experience a‘virtuous circle’ where exportingleads to new innovation, and wherethose innovations then lead to furtherexporting. Over half of all the firmssurveyed (53%) said that a newproduct or service evolved becauseof their business outside the UK.

However, it’s important torecognize that exporting isn’t anautomatic passage to growth and asuccess for everyone. In today’seconomic environment it can be acostly mistake for a business to forgeahead with an export strategy simplybecause growth in its traditional homemarkets is slowing down, somethingthat UKTI is keen to emphasize. Itmust conduct a full and realisticassessment of its business model inthe context of the new export marketsit wishes to enter; this needs toencompass its products, services andcommercial propositions. It isunrealistic to assume that a model thathas worked in a traditional, homemarket can simply be lifted into anoverseas one that is likely to be drivenby significantly different commercialand cultural characteristics.

Such consideration is particularlytrue if, like DAV, you are a peoplebased business providing professionalservices. The European market has alargely consistent and mature viewof professional services and, whilstthere’s no doubt that competition isdriving increasingly sharper deals, it’sstill possible to maintain the kind ofcommercial model that serviceproviders have traditionally enjoyed.But, as we have discovered, it’s awhole new ball game trying to takethat model into, say, Asian or MiddleEastern markets which have a verydifferent view of the commercialrates they are prepared to pay. Unlessyou are highly differentiated,servicing these markets with UKbased staff, with all the cost thisimplies, is very difficult to sustain,particularly if your people are likelyto be deployed in over a long periodof time. In our experience, this modelonly works if you are able to establishan ‘in region’ operational presenceand have access to suitably qualifiedand experienced local resources.Achieving this gives you acommercial model and, if you hireeffectively, people that are calibratedto your ‘local’ market. Leaving asideyour enhanced competitiveness, thisrenders you less susceptible to thingslike currency fluctuations, hiddencosts and cultural aspects. It alsoreduces the likely disruption to UKbased staff who may only be at bestprepared to work overseas forrelatively short periods of time.

So, whilst the UKTI researchindicates that exporting offerssubstantial benefits there are clearlydownsides that must be considered.The fundamental principle is that anybusiness thinking of exporting mustundertake a thorough due diligencebefore setting out down this path. Yourexport business plan needs toconsider a multitude of scenariosspecific to your business model and,most importantly, companies need to

...it’s important torecognize thatexporting isn’t anautomatic passage togrowth and ...success...

Hidden Costs - Continued on page 12

V O L U M E 12, I S S U E 7 P A G E 4

BIS UpdateBureau of Industry and Security

Convicted - Continued on page 12

PHILADELPHIA - Timothy Gormley,52, of North Wales, PA, wassentenced to 42 months in prison forfive counts of violating theInternational Emergency EconomicPowers Act (IEEPA). Gormley wasemployed by Amplifier Research, inSouderton, Pennsylvania, amanufacturer and supplier ofmicrowave amplifiers with bothdomestic and foreign customers. OnNovember 30, 2011, the Departmentof Commerce (DOC), Office ofExport Enforcement, received avoluntary self-disclosure fromAmplifier Research. Many of theirproducts are classified under anExport Control Classification Numberand require a license for export tomost destinations outside of Europe.These amplifiers are controlled forNational Security reasons, and haveapplication in military systems whichinclude radar jamming, weaponsguidance systems, and other uses.Amplifier Research became aware thatGormley had committed numerousviolations of government regulations,

between June 7, 2006 and June 28,2011.

Gormley pleaded guilty onOctober 17, 2012, admitting that hehad altered invoices and shippingdocuments to conceal the correctclassification of amplifiers to beexported so that they would beshipped without the required licenses;listed false license numbers on exportpaperwork for defense articleshipments; and lied to fellowemployees about the status andexistence of export licenses.Gormley’s actions resulted in at least50 unlicensed exports of nationalsecurity sensitive items to destinationsincluding China, India, Hong Kong,Taiwan, Thailand, Russia, Mexico,and other countries. When Gormleyadmitted to the conduct, he explainedit by saying he was “too busy” toobtain the licenses. Gormley claimedhe was overwhelmed at work and thatwas his only excuse. In addition tothe prison term, Judge Pratter orderedthree years of supervised release andfined Gormley $1,000.

North Wales Man Sentenced For IllegallyExporting Goods

Source: http://www.bis.doc.gov/news/2013/doj01172013.htm

WASHINGTON – Hia Soo GanBenson, aka “Benson Hia,” andLim Kow Seng, aka “Eric Lim,”have been extradited fromSingapore to stand trial in the Dis-trict of Columbia in connection withan alleged fraud conspiracy involv-ing the unlawful export of 55 mili-tary antennas from the UnitedStates to Singapore and Hong Kong.

Hia and Seng, both citizens ofSingapore, were arrested bySingaporean authorities in connec-tion with a U.S. request for extra-dition. Each defendant faces onecharge of conspiracy to defraud theUnited States by violating the ArmsExport Control Act. If convicted,each defendant faces a potentialsentence of five years in prison.

The indictment alleges that Hiaand Seng conspired to defraud theUnited States by causing a total of55 cavity-backed spiral antennasand biconical antennas to be illegallyexported from a Massachusettscompany to Singapore and HongKong without the required StateDepartment license. These militaryantennas are controlled for exportas U.S. munitions and are used inairborne and shipboard environ-ments.

Hia and Seng are alleged tohave, among other things, conspiredto undervalue the antennas to cir-cumvent U.S. regulations on the fil-ing of shipper’s export declarationsto the U.S. government. They alsoallegedly used false names and frontcompanies to obtain the antennasillegally from the United States.

Source: http://www.bis.doc.gov/news/2012/doj12212012.htm

Two Extradited From Singapore InConnection With Plot To Illegally

Export Military Antennas

A federal jury in Puerto Rico con-victed a former executive of a Florida-based coastal water freight transpor-tation company for his participationin a conspiracy to fix rates and sur-charges for water transportation offreight between the continental UnitedStates and Puerto Rico, the Depart-ment of Justice announced.

Frank Peake, the former presi-dent of Sea Star Line LLC, was foundguilty of participating in a conspiracy

to fix rates and surcharges for watertransportation of freight between thecontinental United States and PuertoRico from at least as early as late2005, until at least April 2008.

“The coastal shipping price-fix-ing conspiracy affected the price ofnearly every product that wasshipped to and from Puerto Rico dur-ing the conspiracy,” said Bill Baer,

Former Executive Convicted of Price-FixingInvolving International Freight Services

P A G E 5 V O L U M E 12, I S S U E 7

DDTDDTDDTDDTDDTCCCCC Update Directorate of Defense Trade Controls

The highest industry standard ofproficiency offered by IIEI Certifi-cation for those charged with ad-ministration of the InternationalTraffic in Arms Regulations.

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NoticesEffective immediately (1.18.13),

industry must use the updated ver-sion (Version 3) of the DS2032Statement of Registration form. Re-visions include fixing several typosand adding new flow- over instruc-tions to Block 12 advising the ap-plicant to enter the email address ofthe person to receive the approvalletter and who will receive the elec-tronic renewal notice letter. DDTCno longer mails hardcopy approvalletters or renewal letters.

77 FR 76864, December 31, 2012,Public Notice 8135.

Amendment to the InternationalTraffic in Arms Regulations: Afghani-stan and Change to Policy on Pro-hibited Exports

The Department of State isamending the International Traffic inArms Regulations (ITAR) to list Af-ghanistan as a major non-NATO ally,and to make available the use of twoadditional defense export license ex-emptions for proscribed destinations.

The China Nuclear IndustryHuaxing Construction Co., a cor-porate entity owned, and operatedby the People’s Republic of China(PRC), pled guilty to charges it con-spired to violate the InternationalEmergency Economic Powers Act(IEEPA) and the Export Adminis-tration Regulations (EAR).

Federal officials said the pleamarks the first time that a PRC cor-porate entity has entered a plea ofguilty in a U.S. criminal export mat-ter. “In 2010, the Chinese subsid-iary of PPG Industries pled guiltyto the conspiracy to export high-performance coatings for use in thePakistani nuclear reactor,” saidU.S. Attorney Ronald Machen. “In2011, the former managing direc-tor of that subsidiary, a Chinesenational, pled guilty. Now, Huaxing— the PRC-corporate entity thatbought the coatings for applicationin the Pakistani reactor — has ac-cepted responsibility for its role inthe crime. The lesson here is clear:we will pursue violations of U.S.export controls wherever they oc-cur in the world, we will prosecuteboth individuals and corporatewrong-doers, and a corporation’sstatus as foreign-owned, or evenstate-owned, will not bar enforce-ment of those laws in U.S. courts.”

The case’s combined $3 mil-lion in criminal and administrativefines represent the government’scontinued determination to pursuesubstantial monetary penalties forexport violations.

Huaxing is headquartered inNanjing, China. Its guilty plea isthe result of a long-term investiga-

tion of illegal exports of high-per-formance epoxy coatings from theUnited States to the Chashma IINuclear Power Plant in Pakistan,which Huaxing was building as partof a nuclear cooperation pact be-tween the PRC and Pakistan.Chashma II is owned by the Paki-stan Atomic Energy Commission(PAEC), an entity on the Depart-ment of Commerce’s Entity List. .. . .Huaxing agreed to the maximumcriminal fine of $2 million, $1 millionof which will be stayed pending itssuccessful completion of five yearsof corporate probation. The termsof Huaxing’s probation will requireit to implement an export complianceand training program that recognizesHuaxing’s obligation to comply withU.S. export laws.

Through an administrativeagreement with the Department ofCommerce, Huaxing has alsoagreed to pay another $1 million im-mediately and be subject to multiplethird-party audits over the next five

China - Continued on page 12

China Nuclear CorporationPleads Guilty to Pay $3 Million

for Illegal Exports

Former Iraqi TerroristsLiving in Kentucky

Sentenced for TerroristActivities

Two Iraqi citizens living inBowling Green, Ky., who usedimprovised explosive devices(IEDs) against U.S. soldiers inIraq, were sentenced to 40 yearsor more. Read complete story at:http://www.justice.gov/opa/pr/2013/January/13-nsd-122.html

V O L U M E 12, I S S U E 7 P A G E 6

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As a service to exporters, theBureau of Industry and Security(BIS) provides a webpage wheresources of publicly availableinformation on CommodityClassifications can be found.They invite companies toparticipate in this opportunity byproviding information to BIS onwhere Commodity Classificationinformation related to yourproducts may be obtained.

We are taking this action toenhance procedural transparencyin the licensing process and tohelp exporters comply with U.S.export and reexport control laws.

Please be advised that anycompany information posted totheir webpage is forinformational purposes only anddoes not signify any additionalobligations under the EAR. BISwill not validate or be responsiblefor the accuracy of theclassification information, andinclusion on the webpage doesnot denote BIS endorsement of

Commodity Classification Website Solicitation

any company, its employees, or itsproducts or services.

CLASSIFICATIONINFORMATION TABLEIf your company currently has,

or plans to have, Commodity Clas-sification information available onyour company’s website, or an ex-port control point of contact, andyou would like this information tobe accessible via the BIS website,please contact :CommodityClassifications@bis.doc.gov.In your email, provide any of thefollowing information you would liketo be posted on the BIS website:

1) Company name2) General description of theproducts/services3) Commodity classificationinformation website address4) Export control point ofcontact (may be a generaltelephone number or emailaddress)

Source: http://www.bis.doc.gov/commodityclassificationpage.htm

The following lists may berelevant to your export or reexporttransaction. For your convenience,the agencies responsible for theselists have consolidated these listsinto one downloadable file. Toaccess the consolidated list, go towww.Export.gov.

Denied Persons ListA list of individuals and entities

that have been denied export privi-leges. Any dealings with a party onthis list that would violate the termsof its denial order is prohibited.http://www.bis.doc.gov/dpl/default.shtm

Unverified ListA list of parties where BIS has

been unable to verify the end-userin prior transactions. The presence

Compliance and Enforcement

Lists To Check

Lists - Continued on page 10

DDTC Revised Guidelines for thePermanent Export, Temporary Export,

andTemporary Import of Firearms

and Ammunition forU.S. Munitions List Categories I and III

Updated January 2013Click for more: http://www.pmddtc.state.gov/licensing/documents/Guidelines_Firearms.pdf)

P A G E 7 V O L U M E 12, I S S U E 7

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From the ECR Blog

November 29, 2012 - Com-merce Publishes Proposed Ruleto Make the Commerce ControlList Clearer

On November 29, the U.S.Department of Commerce pub-lished a proposed rule to clarifycertain sections of the CommerceControl List to remedy any un-necessary compliance burdenscaused by rules that are overlycomplex, outmoded, inconsistent,or overlapping as a result of ac-cretion. There will be a 60-daywindow for submitting commentsthat will close on January 29.

November 29, 2012 - TheDefense Trade Advisory GroupHolds Meeting to Discuss ExportControl-Related Issues

The Defense Trade AdvisoryGroup (DTAG) held a meeting inWashington to present and dis-cuss the findings from three of itsrecent studies regarding trade indefense industrial goods. The firstdiscussion laid out a list of indus-try priorities for export control re-form, the second included a pro-posal for a new ITAR exemption,and a third was an examinationof proposed changes to ITARbrokering rules. Assistant Secre-tary of State Andrew Shapiro pre-sented keynote remarks and pro-vided a status update for the Ex-port Control Reform effort.

November 28, 2012 - Stateand Commerce Publish Pro-posed Rules for Category XI

President Obama’s Export ControlReform Initiative Update

On November 28, the U.S.Departments of State and Com-merce published proposed rulesfor the transition of certain itemsfrom Category XI of the U.S. Mu-nitions List to the Commerce Con-trol List. Category XI pertains tocontrols for a variety of “MilitaryElectronics”, and there will be a 60-day window for submitting com-ments that will close on January28.

November 5, 2012 - ExportControl Reform Levels the Play-ing Field for Small American Ex-porters

In addition to reducing thecompliance burden for exporters,the Export Control Reform im-provements will make it easier forsmaller American firms to partici-pate in foreign markets and pro-vide after-market support to Al-lies who purchase U.S. systems.The Defense Department consid-ers many parts and components ofthese systems to be less sensitive,so these items will be moved to themore flexible Commerce statutoryauthorities. This will make it easierto export to Allies, thereby en-hancing interoperability. The itemswill remain controlled, but by pri-oritizing U.S. controls, the second-

and third-tier suppliers who makemany of these items for U.S. primeswill no longer lose the after-marketto foreign end-users who design-outU.S. content to avoid the reach ofU.S. controls. Some items mighteven be eligible for a license excep-tion. This will enhance the reliabilityof U.S. suppliers and will be benefi-cial to the health and competitive-ness of the U.S. industrial base, in-cluding maintaining and expandingjobs. Most critically, these changeswill ensure the vitality of the U.S. in-dustrial base to meet future U.S. na-tional security requirements.

For more information, please visitthe ECR Library at:.http://export.gov/ecr/eg_main_023180.asp

Looking for a Job?

www.tradecompliancejobs.com

TradeComplianceJobs.com is aFREE on-line placement clearing-house for individuals, companies andheadhunters seeking to advertisejobs or find employment in the in-ternational arena brought to you byThe International Import-Export In-stitute. Visit:

V O L U M E 12, I S S U E 7 P A G E 8

GDP (purchasing power parity):$196.8 billion (2012 est.)GDP - real growth rate:-1% (2012 est.)GDP - per capita (PPP):$19,800 (2012 est.)Labor force:4.178 million (2012 est.)Labor force - by occupation:agriculture: 4.7%industry: 30.9%services: 64.4% (2010 est.)Unemployment rate:11.2% (2012 est.)Inflation rate (consumer prices):5.6% (2012 est.)Exports:$105.1 billion (2012 est.)Exports - commodities:machinery and equipment 55.3%,other manufactures 30.6%, foodproducts 7.4%, raw materials3.2%, fuels and electricity 3.3%(2009 est.)Exports - partners:Germany 25%, Romania 5.7%,Austria 5.4%, Slovakia 5.4%, Italy5%, France 4.8%, UK 4.6% (2011)Imports:$100.8 billion (2012 est.)Imports - commodities:machinery and equipment 44.7%,other manufactures 41.3%, fuelsand electricity 5.1%, food products,raw materials 6.7%Imports - partners:Germany 24.7%, Russia 8.6%,China 8.4%, Austria 6.2%,Slovakia 4.9%, Poland 4.7%,Netherlands 4.4%, Italy 4.3%(2011)Exchange rates:forints (HUF) per US dollar - 229.5(2012 est.)Internet hosts:3.145 million (2012)Internet users:6.176 million (2009)

Country Profile Hungaryat a Glance

Source: CIA World Fact Book

Hungary

A parliamentary democracy, Hun-gary is mostly flat to rolling plains; hillsand low mountainson the Slovakianborder. Located inCentral Europe,northwest of Ro-mania, it is slightlysmaller than Indi-ana with a temper-ate climate - cold,cloudy, humid win-ters; warm summers.

68% of its population of 9,958,453(July 2012 est.) live in cities and areculturally Hungarian 92.3%, Roma1.9%,and they are: Roman Catholic51.9%, Calvinist 15.9%, Lutheran 3%,Greek Catholic 2.6%, other Christian1%, other or unspecified 11.1%, un-affiliated 14.5% (2001 census). Ninetynine percent of its population is liter-ate.

Hungary has made the transitionfrom a centrally planned to a marketeconomy, with a per capita incomenearly two-thirds that of the EU-27average. The private sector accountsfor more than 80% of GDP. Foreignownership of and investment in Hun-garian firms are widespread, with cu-mulative foreign direct investmentworth more than $70 billion. In late2008, Hungary’s impending inability to

service its short-term debt -brought on by the global financial

crisis - ledBudapest to ob-tain an IMF/EU/World Bank-ar-ranged financialassistance pack-age worth over$25 billion. Theglobal economicdownturn, declin-

ing exports, and low domestic con-sumption and fixed asset accumu-lation, dampened by governmentausterity measures, resulted in aneconomic contraction of 6.8% in2009. In 2010 the new governmentimplemented a number of changesincluding cutting business and per-sonal income taxes, but imposed“crisis taxes” on financial institu-tions, energy and telecom compa-nies, and retailers. The economybegan to recover in 2010 with abig boost from exports, especiallyto Germany, and achieved growthof approximately 1.7% in 2011.Ongoing economic weakness inWestern Europe caused a GDP tofall 1% in 2012. Unemploymentremained high, at more than 11%.

Budapest

Hungary

P A G E 9 V O L U M E 12, I S S U E 7

Soucre: chron.com

Advice from U.S. Customs & Border Protection

Do I need a License to Import Something?

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You do not need a license to actas an importer. However, someitems require a license or permit fromvarious government agencies in or-der to be imported. For more com-plete information, please see ourpublication “Importing Into the U.S.”(http://www.cbp.gov/linkhandler/cgov/newsroom/publications/trade/iius.ctt/iius.pdf) The chapter on“Special Requirements” providesvery complete information. (Somecommon items that may require li-censes or permits are food productsordered from a commercial vendor,plant, animal and dairy products, pre-scription medications,trademarked articlessuch as name-brandshoes, handbags, luggage,golf clubs, toys, etc. andcopyrighted material suchas CDs, DVDs andtapes)

CBP paperwork does require an“importer number” as a means ofidentifying who the final recipient ofthe goods is. If you have a businesstax number with the IRS, this num-ber should be used as the importernumber. If you do not have a busi-ness tax number, you may use yourSocial Security number.

If you do not wish to give yourSSN to a shipper, and your impor-

tation is for personal use, is un-der $2000, and is being clearedby a Customs Broker (very com-mon for goods shipped by cou-rier services), please see our in-formation about using a thirdparty’s Importer Number by typ-ing “Social Security Number” inthe word search field above.

If you have neither a businesstax number nor a social securitynumber, and you are a non-residentof the U.S., you may contact theport where your goods will enter thecountry and ask them to assign animporter number to you by filing a

CBP Form 5106. (http://f o r m s . c b p . g o v / p d f /CBP_Form_5106.pdf)

A license IS required toact as a Customs Broker,which is someone whoclears goods through CBP

on behalf of importers who do notwant to handle the various techni-calities that are involved in import-ing themselves.

If you have ordered somethingfrom an overseas seller over theInternet for your own personal use,you should also see our informationon Internet Purchases at.(http://www.cbp.gov/xp/cgov/trade/basic_trade/internet_purchases.xml)

CBP ...doesrequire an“importernumber”

suggest a rebalancing is under way— the rebirth is leaving the worldlow on power for now and still couldfail if any of the regions don’t pulltheir weight.

“As you go through these ad-justments, it’s quite painful,” said JimO’Neill, chairman of Goldman SachsAsset Management in London. “Butcoming out the other side with a dif-ferent structure, we should have amuch stronger world economy.”

Changing Complexion’“There is a changing complex-

ion in global growth,” he said. “Itultimately means a more balancedworld economy over the longer haul,but before then it will make it harderfor various regions to withstand ex-ogenous shocks and so businesscycles are likely to be shorter.”

How soon the global economycan right itself will be debated thisweek at the annual meeting in To-kyo of the IMF, which serves as thetraffic cop for worldwide imbal-ances. Delegates will be greeted bythe news that the lender anticipateseven worse growth this year thanthe 3.5 percent it projected in July.

Lagarde Outlook“The global economy is still

fraught with uncertainty, still farfrom where it needs to be,” IMFManaging Director ChristineLagarde said.

IMF - Continued from page 1

Source: http://www.bloomberg.com/news/2012-10-07/shift-in-global-growth-engines-signals-gain-after-pain.html

Excerpted from:

V O L U M E 12, I S S U E 7 P A G E 10

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Lists - Continued from page 6

(602) 648-5750 Outside the U.S.

of a party on this list in a transac-tion is a “Red Flag” that should beresolved before proceeding with thetransaction.http://www.bis.doc.gov/enforcement/unverifiedlist/unverified_parties.html

Entity ListA list of parties whose presence

in a transaction can trigger a licenserequirement under the Export Ad-ministration Regulations. The listspecifies the license requirementsthat apply to each listed party. Theselicense requirements are in additionto any license requirements im-posed on the transaction by otherprovisions of the Export Adminis-tration Regulations.http://www.bis.doc.gov/entities/default.htm

Specially Designated Nation-als List

A list compiled by the TreasuryDepartment, Office of Foreign As-sets Control (OFAC). OFAC’sregulations may prohibit a transac-tion if a party on this list is involved.In addition, the Export Administra-tion Regulations require a license forexports or reexports to any partyin any entry on this list that containsany of the suffixes “SDGT”, “SDT”,“FTO”, “IRAQ2” or “NPWMD”.http://www.treas.gov/offices/enforcement/ofac/sdn/

Debarred ListA list compiled by the State De-

partment of parties who are barredby §127.7 of the International Traf-fic in Arms Regulations (ITAR) (22CFR §127.7) from participating di-rectly or indirectly in the export ofdefense articles, including technicaldata or in the furnishing of defenseservices for which a license or ap-proval is required by the ITAR.http://www.pmddtc.state.gov/compliance/debar.html

Nonproliferation SanctionsSeveral lists compiled by the

State Department of parties thathave been sanctioned undervarious statutes. The FederalRegister notice imposing sanctionson a party states the sanctions thatapply to that party. Some of thesesanctioned parties are subject toBIS’s license application denialpolicy described in §744.19 of theEAR (15 CFR §744.19).http://www.state.gov/t/isn/c15231.htm

Source: http://www.bis.doc.gov/complianceandenforcement/liststocheck.htm

ling when you see that the GDP pro-jection for the U.S. is about 2 per-cent, maybe 2.5 percent. Comparethat to the GDP projections forChina (8.8 percent, according to theInternational Monetary Fund).Compare that to India (7.3 percent)and Brazil (4.1 percent).”

Chris Johnston, president ofWorld Trade Center, said the firststep a business should take is to usetrade data to determine where thereis a need and demand for their prod-uct or service. They should thendetermine if there are any barriers,regulatory or otherwise, to meet-ing that need. The final step is toset up agents and distributors in thatmarket.

Seventeen of the 30 companiesHSBC and the trade center exam-ined do business globally, with anaverage of 29 percent of revenuecoming from outside the U.S. Thisincludes AMRI. The Albany-baseddrug discovery company had $207million in revenue in 2011, 43 per-cent of which came from othercountries according to filings withthe U.S. Securities and ExchangeCommission.

Trans World, an entertainmentretailer, and fuel cell maker PlugPower have no overseas revenue,although Plug Power is engaged ina joint venture with French gas dis-tribution company Air Liquide todevelop systems for the Europeanmaterial handling market.

Source: http://www.bizjournals.com/albany/news/2013/01/29/hsbc-tells-businesses-to-think-globally.html

Growth Continued on page 10

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January 18, 2013

The Office of Foreign Asset Controls is revoking General LicenseNo. 7 under the Weapons of Mass Destruction Proliferators SanctionsRegulations, 31 C.F.R. Part 544, effective 12:01 AM Eastern StandardTime, January 19, 2013. General License No. 7 authorized certaintransactions related to the arrest, detention, and judicial sale of the MVAmina (f.k.a. Shere, a.k.a. Iran Tabas, IMO No. 9305192), a vessel onOFAC’s List of Specially Designated Nationals and Blocked Persons.Accordingly, any such transactions are no longer authorized by OFAC.

Revocation of General License No. 7, under the Weapons ofMass Destruction Proliferators Sanctions Regulations

OFAC: Ellman International, Inc. Settles PotentialCivil Liability for Apparent Violations of the Iranian

Transactions Regulations:Ellman International, Inc.

(“Ellman”), of Oceanside, NewYork, has agreed to pay $191,700to settle potential civil liability forapparent violations of the IranianTransactions Regulations, 31 C.F.R.part 560 (the “ITR”).

Under its prior ownership andmanagement, Ellman sold andexported medical equipment to Iran,in apparent violation of § 560.204of the ITR, and engaged theservices of a physician in Iran, inapparent violation of § 560.201 and§ 560.206 of the ITR. The value ofthe relevant transactions totaled$317,211. The transactionsoccurred over a period of

approximately three years, fromearly 2005 to and ending in February2008 when Ellman was then acquiredby a private equity investment group.Upon discovering Ellman’s violationsafter the acqusition, Ellman’s newowners and management self-reported the matter to OFAC.However, the submission wasdetermined not to be a voluntarydisclosure as defined by OFAC’sEconomic Sanctions EnforcementGuidelines, 31 C.F.R.part 501, App. A (“theE n f o r c e m e n tGuidelines”). OFAChad previously beennotified of a rejectedtransaction between Ellman and acustomer located in Iran but did notat that time learn the full scope ofthe activity because Ellman’s priorowners failed to properly respond toOFAC’s inquiry. The apparentviolations do not constitute anegregious case. The base penaltyamount for the apparent violationswas $426,000.

The settlement amount reflectsOFAC’s consideration of the follow-

ing facts and circumstances, pursu-ant to the General Factors under theEnforcement Guidelines: the trans-actions appear to have been under-taken by Ellman’s prior owners will-fully with knowledge that such trans-actions likely constituted violationsof U.S. law—for instance, Ellmanentered into an agreement with aDubai company to act as a middle-man for the sale of Ellman productsto Iran, apparently for the purposeof evading sanctions; Ellman’s se-nior management prior to the 2008change in ownership actively partici-pated in the conduct giving rise tothe apparent violations; Ellman didnot have a sanctions compliance pro-gram in place at the time of the ap-parent violations; the transactionslikely would have been eligible foran OFAC license; Ellman’s purchas-ers and new owners/managementsubstantially cooperated with the in-vestigation by: promptly bringing toOFAC’s attention the full scope ofthe prohibited conduct that had tran-spired within the company and wasdiscovered after its purchase, pro-viding all requested information in a

responsive and well-organized fashion,and agreeing to tollthe statute of limita-tions and extend thetolled period severaltimes; OFAC has no

record of prior sanctions enforce-ment matters involving Ellman; andthe new owners/management ofEllman undertook significant reme-dial measures, including implement-ing a sanctions and export compli-ance program.

PenaltyPenaltyPenaltyPenaltyPenalty$426,000$426,000$426,000$426,000$426,000

Want a promotionor pay raise?

See artcile top of page 15

V O L U M E 12, I S S U E 7 P A G E 12

Disaster - Continued from page 1

reached for comment, thoughBuenos Aires dealer Adrián Santossays “about 500” BMWs packed thehuge lots at the car port 55 milesnorthwest of the city. During the first10 months of 2011, overall BMWsales plunged by half, according toArgentina’s car dealers association.

After months of negotiations,Echeagaray figured out a fix. Thegovernment agreed to let in BMW’svehicles as long as the company’sArgentine subsidiary exported anequivalent amount of upholsteryleather, car parts, and…processedrice. Echeagaray worked a deal withthe Ministry of Industry to get thenecessary import permits.

He wasn’t the only auto execu-tive taking a crash course in the agri-cultural export business. To bring in$8 million in cars, the local Porscheimporter agreed to export olives andMalbec wine. Subaru agreed to ex-port chicken feed. Hyundai begansending soy flour to Vietnam. AtMitsubishi, they started selling pea-nuts.

Source: www.businessweek.com/articles/2012-11-08/argentinas-interna-tional-trade-disaster

China - Continued from page 5

years to ensure the efficacy of itscompliance with U.S. export laws.

Huaxing’s guilty plea is relatedto the December 2010 guilty plea ofPPG Paints Trading (Shanghai) Co.Ltd. (PPG Paints Trading), a Chi-nese subsidiary of Pittsburgh-basedPPG Industries, to a four-count in-formation in the U.S. District Courtfor the District of Columbia. PPGPaints Trading and its parent com-pany, PPG Industries, paid $3.75million in criminal and administrativefines and more than $32,000 in res-titution.

In November 2011, Xun Wang,the highest ranking executive at theChinese PPG subsidiary, pleadedguilty to conspiracy and agreed tocooperate with the government’s in-vestigation.

(Original Source:www.corporatecrimereporter.com/news/200/chinanuclearguilty12032012/)[Reprinted from Ex/Im Daily Update]

Assistant Attorney General in chargeof the Department of Justice’s Anti-trust Division. “This successful pros-ecution shows that the division willhold accountable high-level execu-tives who perpetuate these crimes.”

Sea Star pleaded guilty on Dec.20, 2011, and was sentenced byJudge Daniel R. Dominguez to pay a$14.2 million criminal fine for its rolein the conspiracy from as early asMay 2002, until at least April 2008.Sea Star transports a variety of cargoshipments, such as heavy equipment,perishable food items, medicines andconsumer goods, on scheduled oceanvoyages between the continentalUnited States and Puerto Rico.

According to evidence presentedat trial, Sea Star, Peake and co-con-spirators carried out the conspiracyby agreeing during meetings andcommunications to allocate custom-ers of Puerto Rico freight servicesand to rig bids and fix the rates andsurcharges to be charged to purchas-ers of water transportation of freightbetween the continental United Statesand Puerto Rico. The department saidthe conspirators also engaged inmeetings for the purpose of moni-toring and enforcing adherence to theagreed-upon rates and sold PuertoRico freight services at collusive andnoncompetitive rates.

Peake was convicted of pricefixing in violation of the ShermanAct, which carries a maximum pen-alty of 10 years in prison and a $1million fine for individuals. The maxi-mum fine may be increased to twicethe gain derived from the crime ortwice the loss suffered by the vic-tims of the crime, if either of thoseamounts is greater than the statutorymaximum fine.

Source: http://www.justice.gov/opa/pr/2013/January/13-at-126.html

Convicted - Continued from page 4

currently offer. People the worldover want skills and learning thatdirectly support their career oppor-tunities. That is the way we havealways done it. That is why our staffis so excited. All of our trademarkedprograms under development will of-fer our practical, career advancingeducation and training.

As 2013 unfolds, you can besure that our school’s entire staff iseager to help our students worldwidegain the knowledge, skills and abili-ties they need to help keep interna-tional trade safe, meet the needs oftheir customers, and foremost pros-per as trade increases.

Thank you for your continuedstrong support and belief in us. Bewell.

Year 2013 - Continued from page 2

understand what it is that they aretrying to achieve and why, and howwell suited their business is toexporting. It is very easy to get carriedaway with the promise that exportingappears to offer, particularly forfirms who are experiencing slowergrowth rates in their traditional homemarkets due to the current economicenvironment. But normal businessrules apply and an effective duediligence may show that, in the end,export business may be harder andless profitable than the equivalentgenerated in this country.

Hidden Costs - Continued from page 3

Source: www.internationaltrade.co.uk/articles.php?CID=1&SCID=&AID=1508&PGID=3

V O L U M E 12, I S S U E 7P A G E 13

IIEI Certification

www.industrycertification.org

“The Global Trade Certification Standard Authority”

(877) 299-7637 (U.S. only)(602) 792-1321

Email: info@industrycertification.org

A service of International Trade Certification Authority Inc.®TM

The Bureau of Industry and SecurityWestern Regional Office

PresentsThe 8th Annual Export Control Forum

February 25-26, 2013Newport Beach, California

The Export Control Forum is a one-and-a-half day program dedicated to bringing thebusiness community up-to-speed on the latest initiatives underway in the export control field,including the latest developments in the Export Control Reform initiative.

Over the day-and-a half program, you will hear key policy management, technical, legal,and enforcement personnel from the Bureau of Industry and Security and other relevant agen-cies provide detailed information on recent changes and those contemplated. Day one willconclude with a networking reception, offering you the opportunity to mingle and discuss issuesof concern with the presenters and other participants. On day two, we will continue in plenarysession; there will be no breakout sessions as in previous years.

For those of you who have requested an Update-like offering on the west coast, this is it!The streamlined day-and-a-half format is intended to provide a lot of value in a package thatfits into your busy schedule.

Location/time

The Export Control Forum will be held February 25-26, 2013 at the Radisson Hotel, located at 4545MacArthur Boulevard, Newport Beach, CA 92660. Registration and continental breakfast will beginat 7:00 AM on day one. The Forum sessions will run from 8:30 AM to 5:00 PM. The day willconclude with a reception from 5:15 PM to 7:15 PM. Day two will commence with a continentalbreakfast at 7:00 AM. The event concludes at noon on Tuesday.

Registration

Advance registration is required. The fee for early registration is $525.00 per person from December13, 2012 – February 15, 2013. The fee for late registration is $550.00 per person from February 16,2013 – February 20, 2013. The fee includes continental breakfast, breaks, lunch, and trainingmaterials. Click the following link for online registration via credit card or check payments. http://

www.cvent.com/events/8th-annual-export-control-forum/event-summary-8baaf6d4fa054b97a8f76830c2e23137.aspx

BIS logo trademark reprinted with permission.

HAS-103 Critical Thinking AnalysisBUS-102 Introduction to BusinessBUS-111 Introduction to Customer ServiceFAE-230 Business Accounting ConceptsBUS-403 Global MarketingBUS-113 Topics in Contemporary BusinessBUS-303 International Business EthicsTRD-307 Understanding the EARTRD-320 Ethics in Trade ComplianceTRD-201 Exporting/Importing EnvironmentSCM-125 Port AuthoritySCM-202 21st Century International LogisticsSCM-379 WarehousingSTM-385 Information Systems in a Global BusinessHAS-188 Introduction to The Revolutionary WarSTM-106 Computing EssentialsTRD-308 Mastering ITAR ExemptionsTRD-129 ImportingTRD-304 Customs Broker Exam Prep CourseTRD-350 China Export Controls OverviewBUS-404 Researching the Global VillageTRD-365 Ethics in Import ComplianceTRD-214 Trade Compliance Environment - ITRD-309 Commerce License Exceptions

V O L U M E 12, I S S U E 7 P A G E 14

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This award that comes from our students says it all.

If there was an instructor who you felt exceeded your ex-pectations or who made a profound impact on you personally,please share those experiences with Caulyne Barron, ChiefAcademic Officer and nominate him or her to be our FacultyMember of the Year.

Each year we honor faculty members who, through yourfeedback and our own internal academic quality control sys-tems, are seen to provide the critical spark of learning, goingthe extra mile for students and making learning a personallyrewarding experience.

If you have an experience that you’d like to share, pleaseemail Caulyne at cbarron@dunlap-stone.edu (or Caulyne Barroninside the classroom) with the subject line Instructor of theYear. Your email should include the instructor’s name, the classyou took from them and why you think they are an exemplarycandidate for instructor of the year.

Faculty Member of the YearNominations Now Open

Phoenix, AZ (PRBuzz.com)-- Dunlap-Stone University's Collegeof Arts & Letters is pleased to announce its new Bachelor ofScience degree in Health Care Administration has met the school'sdemanding standard to officially be listed as a Professionally Sig-nificant Degrees® program. This distinction sets the program apartfrom other schools' healthcare offerings that can not make thisclaim. The new online degree's first classes begin January 10th.Dunlap-Stone is now accepting a limited number of applicationsfor students wanting to enter this career-enhancing program. Earlyregistration is recommended.

Those familiar with Dunlap-Stone's other programs knowthe school only offers programs that make a difference in people'slives. Two and a half years in development with industry leaders,the health care degree not only provides relevant job skills neededin today's competitive job market, but also the knowledge neces-sary for people to advance their careers. Those already workingwithin the health care arena will immediately recognize the practi-cal value contained in this program and how it will impact theircareer. A recent independent survey of all private and public col-leges and universities showed that although noted for educationexcellence, Dunlap-Stone University is among the lowest costtuition schools in the nation.

Bachelor in Health Care AdministrationDegree Debuts

Click for complete details about this degree program:http://www.dunlap-stone.edu/programs/degree-programs/bs-health-care-administration

TRD-304 Customs Broker Exam Prep CourseTRD-307 Understanding the EARTRD-311 Documentation for Export ComplianceTRD-306 Understanding ITARBUS-118 Introduction to Business WritingBUS-401 Global CultureFAE-263 Principles of MicroeconomicsFAE-302 Global Finance MethodsHAS-105 Writing Across the CurriculumHAS-132 Introduction to PsychologyMGT-135 Introduction to LeadershipMGT-335 Modern Management PrinciplesMGT-402 Global Strategic ManagementMGT-445 Competitive Human Resource ManagementSCM-376 Purchasing in the Global MarketplaceTRD-225 Documentation for the Global VillageHAS-184 Introduction to the Short StoryHAS-260 Terrorism in the 21st CenturyTRD-141 Incoterms® 2010TRD-143 Introduction to CTPATTRD-215 Trade Compliance Environment 2TRD-299 Agreements Under the ITARTRD-257 Empowered Officials EssentialsTRD-322 Understanding NAFTA

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TRD-318 Introduction to OFACTRD-101 Getting Started in International TradeBUS-405 Global Business PlanTRD-216 Trade Compliance Environment 3TRD-307 Understanding the EARTRD-366 Topics in Import ManagementTRD-306 Understanding ITARTRD-320 Ethics in Trade ComplianceTRD-331 University Export Compliance EnvironmentBUS-403 Global MarketingBUS-440 Legal Environment of BusinessFAE-230 Business AccountingFAE-450 International EconomicsHCA-133 Introduction to Public HealthMGT-345 Organizational BehaviorSCM-412 Global Supply Chain StategiesSTM-160 Statistics in BusinessTRD-140 Importing Duties and RegulationsTRD-311 Documentation for Export Compliance

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V O L U M E 12, I S S U E 7P A G E 15

D

S Dunlap- Stone University

The students shown here have demonstratedoutstanding “A” performance .

Dunlap-Stone UniversityStudent Honor Roll

Honor - Distinction - Excellence

Enrollments in degree pro-grams are up 50% over last year.The biggest reason for the increasemay be the reported success of stu-dents. A survey conducted last fallas part of the university’sreaccredidation effort showed40% of student respondents saidthey got a promotion or pay raiseas a result of completing coursesor programs at the school. Thegrowth does not surprise the

university’s president, Dr. DonaldBurton. “More and more studentsare being referred to us from otherstudents. Their career success attrib-uted by them to gaining valuableskills, knowledge and abilities at ourschool is very rewarding. It is onlynatural they would refer their friendsto us.” Dr. Burton said that this dem-onstrates the overall value of the uni-versity and particularly the school’strademarked Professionally Signifi-

cant Degrees® program that sets theschool apart from many other aca-demic institutions that don’t supportcareer growth in their programs. Hesaid it takes a total effort from fac-ulty, staff and administration to helpstudents so significantly. Classesstart year-round. Interested poten-tial students should contact a friendlyEnrollment Advisor at (800) 474-8013 or (602) 648-5750.

Professionally Significant Degrees®®®®® Get Vote of Confidence

Allen, Connie - VAAlvares, Dana - ORArvick, Jeffrey - VABaldwin, David - TXBambino, Katrina - ONBevins, Janna - GABoland, Patsy - IABoor, Scott - ILBostic, Laura - ILBrei, Kenly - NYBreitkopf, Stefan - PABrooks, Janet - DCBrown, Connie - MNBrown, Lacey - NHCalvo, Francisco - FLCharles, Merari Ibarra - TXChu, Valerie - ILColon, Catalina - NJConner, Trenton - ILConroy, Michael - ILCrampton, Ulku - VACrawford, Karen - ONDahlgren, Jennifer - VADavis, Marcia - CADawson, John - VADelaney, Kevin - ILDeporter, Carol - TNDewitte, Anastasiya - MAEastman, Lina - ILEngland, Joseph - VAEsail, Ana - CAFaso, Frank - ILFelton, Carla - AZFlynn, Barbara - INFoley, Elizabeth - NJ

French, Martha - GAGalarza, Carlos - SCGriffin, Jennifer - VAGroseclose, Teresha - VAGurski, Kim - MDHaertling, Susan - MOHall-Cloutier, Tricia - NCHancock, Elizabeth - VAHarding, Steve - ILHarper, Kimberly - TXHelk, Torsten - NJHimes, Cristina - MDHoberecht, Claire - WAHornschemeier, Joan - OHJackson, Collings - VAJones, Matthew - CAJones, Ray - NVJou, Michael - CAJuergens, Douglas - IAKelley, Rachel - TXKendrick, Lisa - NYKing, Cinnamon - SDKinnear, Ji - CAKramer, Deborah - PAKupietz, Tammy - WILabine, Michael - GALamberson, Rashelle - TXLambert, Kimberly - AZLataxes, Patricia - LALong, Derrick - ONMadhu, Dana - TXMarch, Rhonda - VAMason, Terrance - VAMay, Ken - TXMayfield, Robert - IL

McQuade, Sarah - AZMichaelis, Katrina - IDMiddleton, Laura - ILMurphy, Aaron - MDO’Connell, Megan - NYPatel, Viky - ILPerkins, Janet - NVPittas, Kristen - MDPlitt, Jurgen - CAPriskey, Robert - MIPritula, Kimberly - NHRoberts, Laura - AZRoden, William - FLRubio, Rose - CORulavage, Robert - PARussell, Donald - MIRutstein, Gayle - TXRyan, Andrew - NYRyan, Betty - NYShankey, Denise - WIShi, Haichuan - KYSmal, Cornelius - KYSmith, Kristin - COSmith, Michael - NMSteckel, Heather - ALButner, Stacy - FLTorelli, Linda - PAUlibarri, Bret - MAValentine, Joe - NCVargas, William - GAVoorhees, Richard - TXWeber, John - CAWesley, Jody - COWood, Stephanie - TXZamora, Nicole - AZZinsli, Jeffery - MN

As of Jabuary 28, 2013

Visit us Online at: http://iiei.dunlap-stone.edu

19820 North 7th Street, Suite 100 NEW ADDRESSPhoenix, Arizona USA 85024Phone: (800) 474-8013 Outside U.S. (602) 648-5750Fax: (602) 648-5755Email: info@dunlap-stone.edu

The InternationalImport-Export Institute

College of Arts & Sciences

Visit our Website at www.dunlap-stone.eduor Call (800) 474-8013 - Outside the U.S. 01-602-648-5750

Great careers don’t just happen.They are planned!

Speak to an Academic Advisor today about your goals for tomorrow!

Bachelor of ScienceBachelor of ScienceBachelor of ScienceBachelor of ScienceBachelor of ScienceHealth Care AdministrationHealth Care AdministrationHealth Care AdministrationHealth Care AdministrationHealth Care Administration

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