By Jason Dickstein, President, MARPA
We are always looking for ways to make compliance easier. Aviation is a global business, and sometimes you have look far and wide for the part you need. Many aircraft parts are regulated by the United States for export purposes, and it is important to ensure that you have an adequate compliance system in place to help promote effective export compliance when your parts supply chain involves an export transaction.
Aerospace companies should have compliance systems that help them identify which regulatory bodies have jurisdiction over your export transaction and how your aircraft parts are regulated for export purposes. They should be able to lead your personnel through the export compliance maze and they should identify when a license may be needed. They should also help support the collection of information needed for an electronic export information (EEI) filing. Such systems should also be able to address common aerospace export issues like deemed export (which can arise even if you do not export articles out of the United States), aircraft parts returned to the U. S. for repair, and license exceptions for AOG (aircraft-on-ground) situations.
Most people know that the United States regulates international trade (exports from the U. S.) through either the State Department (for defense-related articles) or the Commerce Department (including civil aircraft articles).
About a year ago, State and Commerce published new regulations that make it much easier to identify which agency has jurisdiction. Many companies revamped their compliance programs in 2014 in order to reflect the new regulatory regime. If you haven’t made export compliance a procedure-based part of your operations, then it is not too late!
But the one agency that has not gotten a lot of notice has been the Treasury Department. The Treasury Department has a number of ways that it limits U. S. exports in order to advance U. S. interests. It has lists of people and parties with whom you may not perform export business, and it also has programs, both country-based (like the Iran sanctions program) and situation-based (like sanctions against those who are part of a transnational criminal organizations).
The Treasury Department office with jurisdiction over export programs is the Office of Foreign Asset Control (OFAC). Their name is practically synonymous with exporting; whenever I mention exports, I always hear someone muttering “OFAC.”
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