Commerce License Exceptions - IIEI-309

Course Description: This six-week course provides an in-depth exploration and detailed understanding of the use of License Exceptions in the Export Administration Regulations (EAR). The Bureau of Industry and Security (BIS) of the US Department of Commerce administers these regulations. With the knowledge gained in this course, students will be able to correctly utilize License Exceptions for exports and re-exports when allowed by the EAR. 

Prerequisite: Understanding the EAR (IIEI-307) or instructor approval.

Course Credit: 3 Credit Hours

Major Course Topics & Course Outcomes

As a result of the group and individual activities included in this course, the student will acquire the following knowledge and skills that can be applied to the workplace:

Background

• Determine when items are subject to the ITAR
• Understand the Wassenaar Arrangement is and how it effects the CCL
• Make sense of the CCL
• Describe the Reasons for Control
• Define prohibitions, restrictions, and embargoes

License Exceptions

• Discuss License Exceptions
• Identify the Concept of “ECCN” (List) Based License Exceptions
• Review the Concept of “Transaction” Based License Exceptions
• Define the Purpose of License Exceptions  

Review of all License Exceptions

• Determine if an item is eligible for a License Exception
• Break down how to make a decision to use a License Exception
• Recognize Specific Conditions and Restrictions of Each License Exception
• Differentiate the Notifications, Reviews, and Reporting Requirements of Specific License Exceptions

Control Requirements of Encryption License Exceptions

• Identify the General Requirements of Encryption Items
• Classify the Specific Encryption Classification Requirements
• Distinguish the Specific Encryption Notification and Review Requirements
• Examine the Specific Encryption Reporting Requirements 

Recordkeeping and Special Reporting

• Demonstrate the ability to keep adequate records of the exceptions made using the CCL.
• Discuss the Special Reporting Required under the EAR for License Exceptions.

License Exception Problems and Solutions

• Assess potential problems and determine solutions.  

Definition of Terms

• Define the terminology used in the EAR and by BIS

Course Materials:

Required course materials for this course are listed below.

Commerce Control List Overview and the Country Chart (EAR, Part 738)

License Exceptions (EAR, Part 740),

Country Policy -- CCL Based Controls EAR Part 742) (Selected Readings)

Special Reporting (EAR, Part 743),

Embargoes and Other Special Controls (EAR Part 746)

Definition of Terms (EAR Part 772)

Commerce Control List (EAR, Part 774),  

Please note that textbooks are subject to change. Please contact your advisor before purchasing the textbook for your class to confirm.