Thursday, July 25, 2013

Did You Miss It?

The US Department of Commerce (DOC), Bureau of Industry and Security (BIS), finished their annual three-day 2013 Update Conference on Export Controls and Policy in Washington DC today on a high note.  The concluding Roundtable Discussions and the Q&A at many of the Main Conference Sessions were particularly outstanding! 

The theme of Update this year is “Fulfilling the Promise.”  Perhaps a more appropriate title is “Fulfilling the Promise-A Work in Progress.”  Nevertheless, DOC and BIS leadership along with a dedicated conference team did a great job coordinating, executing the event and laying important groundwork for Export Control Reform (ECR) and the migration of thousands of articles from State Department to Commerce Department jurisdiction.

Most of the presentations are already available on the newly designed BIS website at http://www.bis.doc.gov/.  Do yourself and your organization a big favor-- download them, review them and share the information broadly with counterparts.  They include a great deal of excellent, timely and useful ECR related material that will help you and your organization make what could be a very turbulent transition!  

 

Saturday, July 6, 2013

Three Raytheon Settlements Provide Insight into Evolving Perspectives on Compliance and Enforcement at the Directorate of Defense Trade Controls (DDTC

If you only read the most recent Raytheon-DDTC settlement documents you do not get a complete picture of their compliance culture, history over the last 15 years, how the State Department used to handle cases and how they approach them now, especially in the area of mandated compliance measures.

If you want some valuable additional insight and telling trend information, check out the one page Raytheon-DDTC Settlements Summary/Comparison at http://www.scribd.com/doc/152123272/Raytheon-DDTC-Settlements-Summary
or http://www.slideshare.net/jpriecko/raytheon-ddtc-settlements-summary-070613.

It provides an interesting side-by-side comparison of the April 2013, February 2003 and October 1999 Raytheon settlements with the DDTC. A few significant differences are worth noting. Is there one thing in particular that seems most obvious?

What do you attribute the differences over time to? What do you think are the most important takeaways when considering all three of the Raytheon-DDTC settlements?

April 30, 2013, Raytheon Settlement Summary - Important Lessons Learned

A concise one-page summary of the April 30, 2013, US Department of State settlement with the Raytheon Company is now available online at: http://www.slideshare.net/jpriecko/raytheon-043013-settlement-summary-060613

It is a bite-size tool in a template format summarizing material facts from the Proposed Charging Letter, Consent Agreement and Order.  For more on the lessons learned and key takeaways, read the narrative introductory text on either of the above sites.