Export Compliance Program

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Export Compliance Program

What is it?

If a group or company works in a field which is subjected to export control law compliance, it must adopt some strategy to prevent violations. This strategy must be well planned and it must be formalized in a set of documents and practices that may be called an export compliance program”.

The ideal situation is one in which these practices become part of the group’s culture over time. Therefore, the adoption of an export compliance program involves the implementation of a formal program for following export control requirements. The program should address the following:

  1. Appointing someone to be in charge of export control compliance
  2. Establishing written policies and procedures for performing activities that are subject to export control
  3. Conducting adequate training
  4. Adopting procedures for the receipt, handling, storing and shipping of export-controlled items
  5. Adopting a procedure for dealing with foreign nationals 
  6. Adopting an auditing procedure
  7. Adopting procedures in case of compliance violations

Figure 1: Elements of  a compliance program

Academic space payload teams can develop their own export compliance program based off of NASA's policies and procedures. These can be found in NPR 2190.1C, the NASA Export Control Program. More information about NASA's approach to export control can be found on the Office of International and Interagency Relations' website.