KEY ELEMENTS TO AN EFFECTIVE EXPORT CONTROL COMPLIANCE PROGRAM

One billion dollars: That was the fine ZTE agreed to pay in 2018 in order to lift a denial order issued by the United States government in response to export control violations. Similarly, Huawei’s CFO was indicted in December 2018 for alleged export control violations with respect to Iran. As these cases indicate, penalties for violating export control regulations can be high and include criminal charges.

Further, as discussed in my previous article “6 Things Any Entrepreneur Should Know About Export Controls,” U.S. export control law affects a broader group of companies than many people realize. Thus, it can be vitally important to have an export control compliance program. This article seeks to identify key elements to such a program.

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