Podcast
Questions and Answers
What is the purpose of part 764 as described in the text?
What is the purpose of part 764 as described in the text?
- To provide guidelines for criminal prosecution
- To list all the countries involved in the EAR
- To specify conduct that constitutes a violation of ECRA and the EAR (correct)
- To establish protective measures for individuals
Which violations are described in part 760 of the EAR?
Which violations are described in part 760 of the EAR?
- Criminal violations
- Administrative violations
- Violations related to protective measures
- Antiboycott violations (correct)
Who can impose administrative sanctions according to the text?
Who can impose administrative sanctions according to the text?
- State Department
- BIS (Bureau of Industry and Security) (correct)
- United States Congress
- Department of Justice
What actions are prohibited by ECRA and the EAR?
What actions are prohibited by ECRA and the EAR?
What is the function of sections 11A, B, and C of the Export Administration Act (EAA) as mentioned in the text?
What is the function of sections 11A, B, and C of the Export Administration Act (EAA) as mentioned in the text?
What types of actions are covered by part 764 unless otherwise stated?
What types of actions are covered by part 764 unless otherwise stated?
What type of penalties are statutory sanctions according to the text?
What type of penalties are statutory sanctions according to the text?
Which agency is responsible for seizing and forfeiting property related to export law violations?
Which agency is responsible for seizing and forfeiting property related to export law violations?
What is the consequence of failing to report potential export control violations?
What is the consequence of failing to report potential export control violations?
Which department may deny licenses for export or reexport of defense articles to individuals convicted of specified criminal offenses?
Which department may deny licenses for export or reexport of defense articles to individuals convicted of specified criminal offenses?
Under what circumstances is voluntary self-disclosure considered a mitigating factor?
Under what circumstances is voluntary self-disclosure considered a mitigating factor?
What penalties does the OEE decide upon after receiving voluntary self-disclosure?
What penalties does the OEE decide upon after receiving voluntary self-disclosure?
What kind of actions can the Department of Defense take against individuals violating export control laws?
What kind of actions can the Department of Defense take against individuals violating export control laws?
Who should be notified if a person learns of an export control violation under the EAR?
Who should be notified if a person learns of an export control violation under the EAR?
What distinguishes reporting requirements in §764.4 from other reporting provisions?
What distinguishes reporting requirements in §764.4 from other reporting provisions?
In what situations do the provisions related to voluntary self-disclosure NOT apply?
In what situations do the provisions related to voluntary self-disclosure NOT apply?
What is the maximum monetary civil penalty for each violation under the EAR?
What is the maximum monetary civil penalty for each violation under the EAR?
What consequence may be imposed if a person violates ECRA, the EAR, or any other statute set forth at 50 U.S.C. 4819(e)(1)(B)?
What consequence may be imposed if a person violates ECRA, the EAR, or any other statute set forth at 50 U.S.C. 4819(e)(1)(B)?
Under what authority can an order denying export privileges be imposed?
Under what authority can an order denying export privileges be imposed?
What may happen to a person's export privileges under a denial order?
What may happen to a person's export privileges under a denial order?
What is the maximum fine for an individual who willfully commits an unlawful act described in 50 U.S.C. 4819(a)?
What is the maximum fine for an individual who willfully commits an unlawful act described in 50 U.S.C. 4819(a)?
What may be imposed in addition to criminal and administrative sanctions for conduct violating ECRA and the EAR?
What may be imposed in addition to criminal and administrative sanctions for conduct violating ECRA and the EAR?
Under what conditions can the payment of a civil penalty be deferred or suspended?
Under what conditions can the payment of a civil penalty be deferred or suspended?
What is the primary consequence of conduct violating ECRA, the EAR, or any order issued thereunder?
What is the primary consequence of conduct violating ECRA, the EAR, or any order issued thereunder?
Who can authorize actions otherwise prohibited by a denial order?
Who can authorize actions otherwise prohibited by a denial order?
What may happen to a person acting as an attorney, consultant, or freight forwarder if they violate regulations before BIS?
What may happen to a person acting as an attorney, consultant, or freight forwarder if they violate regulations before BIS?
What type of activities are prohibited by General Prohibition Ten at §736.2(b)(10) of the EAR?
What type of activities are prohibited by General Prohibition Ten at §736.2(b)(10) of the EAR?
In accordance with the EAR, what can BIS do to a person convicted of an offense specified in §11(h) of the EAA?
In accordance with the EAR, what can BIS do to a person convicted of an offense specified in §11(h) of the EAA?
Which activities relating to items subject to the EAR are covered by §764.2(e) and General Prohibition Ten?
Which activities relating to items subject to the EAR are covered by §764.2(e) and General Prohibition Ten?
What is required for activities involving installed base items in Libya under §764.2(e) where no license is needed?
What is required for activities involving installed base items in Libya under §764.2(e) where no license is needed?
What is prohibited by General Prohibition Ten at §736.2(b)(10) if there is knowledge of a violation?
What is prohibited by General Prohibition Ten at §736.2(b)(10) if there is knowledge of a violation?
What must be known about an item for General Prohibition Ten to apply?
What must be known about an item for General Prohibition Ten to apply?
Which of the following actions is prohibited by ECRA, the EAR, or any order, license, or authorization issued thereunder?
Which of the following actions is prohibited by ECRA, the EAR, or any order, license, or authorization issued thereunder?
What is prohibited regarding solicitation and attempt of violations?
What is prohibited regarding solicitation and attempt of violations?
Which of the following actions related to conspiracy is prohibited?
Which of the following actions related to conspiracy is prohibited?
Which of the following actions related to knowledge of a violation is prohibited?
Which of the following actions related to knowledge of a violation is prohibited?
What is prohibited regarding misrepresentation and concealment of facts?
What is prohibited regarding misrepresentation and concealment of facts?
What is stated regarding representations, statements, and certifications made by any person?
What is stated regarding representations, statements, and certifications made by any person?
What is prohibited regarding evasion?
What is prohibited regarding evasion?
What is prohibited regarding reporting and recordkeeping requirements?
What is prohibited regarding reporting and recordkeeping requirements?
What is stated regarding altering licenses, authorizations, export control documents, or orders?
What is stated regarding altering licenses, authorizations, export control documents, or orders?
What is prohibited regarding denial orders issued by BIS?
What is prohibited regarding denial orders issued by BIS?
What is the primary factor considered in determining administrative sanctions for voluntary self-disclosure?
What is the primary factor considered in determining administrative sanctions for voluntary self-disclosure?
What discretion does the Office of Export Enforcement (OEE) have regarding voluntary self-disclosure?
What discretion does the Office of Export Enforcement (OEE) have regarding voluntary self-disclosure?
What is the effect of voluntary self-disclosure on potential criminal prosecution?
What is the effect of voluntary self-disclosure on potential criminal prosecution?
For a firm to be considered as having made a voluntary self-disclosure, what condition must be met?
For a firm to be considered as having made a voluntary self-disclosure, what condition must be met?
What rights or benefits are conferred by the provisions regarding voluntary self-disclosure?
What rights or benefits are conferred by the provisions regarding voluntary self-disclosure?
What should a person wanting to make a voluntary self-disclosure do initially?
What should a person wanting to make a voluntary self-disclosure do initially?
How should the initial notification of a voluntary self-disclosure be made?
How should the initial notification of a voluntary self-disclosure be made?
What information should be included in the initial notification of a voluntary self-disclosure?
What information should be included in the initial notification of a voluntary self-disclosure?
What is the time frame for submitting a complete narrative account after the initial notification?
What is the time frame for submitting a complete narrative account after the initial notification?
If it is not practical to make the initial notification in writing, what should be done?
If it is not practical to make the initial notification in writing, what should be done?
What is the recommended time period for reviewing export-related transactions when conducting a voluntary self-disclosure?
What is the recommended time period for reviewing export-related transactions when conducting a voluntary self-disclosure?
What is the consequence of failing to disclose violations that are not voluntarily disclosed?
What is the consequence of failing to disclose violations that are not voluntarily disclosed?
What information should be included in the narrative account provided to OEE during a voluntary self-disclosure?
What information should be included in the narrative account provided to OEE during a voluntary self-disclosure?
What types of supporting documentation should accompany the narrative account in a voluntary self-disclosure?
What types of supporting documentation should accompany the narrative account in a voluntary self-disclosure?
Who should sign the certification statement required as part of a voluntary self-disclosure?
Who should sign the certification statement required as part of a voluntary self-disclosure?
What is the purpose of including a description of mitigating circumstances in the narrative account?
What is the purpose of including a description of mitigating circumstances in the narrative account?
What is the risk of requesting an extension for submitting the narrative account shortly before the deadline?
What is the risk of requesting an extension for submitting the narrative account shortly before the deadline?
What should a person making a voluntary self-disclosure do with relevant documents not attached to the narrative account?
What should a person making a voluntary self-disclosure do with relevant documents not attached to the narrative account?
What is the consequence of making false or misleading representations in connection with a voluntary self-disclosure?
What is the consequence of making false or misleading representations in connection with a voluntary self-disclosure?
What is the purpose of providing a description of the review conducted in the narrative account?
What is the purpose of providing a description of the review conducted in the narrative account?
What is the primary purpose of voluntary self-disclosures according to the text?
What is the primary purpose of voluntary self-disclosures according to the text?
Where should voluntary self-disclosures or related correspondence be submitted?
Where should voluntary self-disclosures or related correspondence be submitted?
What action can the Office of Export Enforcement (OEE) take after receiving a voluntary self-disclosure?
What action can the Office of Export Enforcement (OEE) take after receiving a voluntary self-disclosure?
What describes how BIS typically exercises its discretion regarding administrative enforcement cases?
What describes how BIS typically exercises its discretion regarding administrative enforcement cases?
What action can a person making a voluntary self-disclosure request from BIS?
What action can a person making a voluntary self-disclosure request from BIS?
If a person making a voluntary self-disclosure is granted permission by BIS to engage in otherwise prohibited activities, what is the implication?
If a person making a voluntary self-disclosure is granted permission by BIS to engage in otherwise prohibited activities, what is the implication?
How can a person request a license to reexport items that are the subject of a voluntary self-disclosure?
How can a person request a license to reexport items that are the subject of a voluntary self-disclosure?
What should a person state in a request for reexport authorization if they know the items are the subject of a voluntary self-disclosure?
What should a person state in a request for reexport authorization if they know the items are the subject of a voluntary self-disclosure?
What administrative measure can BIS take to prevent the occurrence of an imminent violation, according to the text?
What administrative measure can BIS take to prevent the occurrence of an imminent violation, according to the text?
What can BIS do based on a criminal conviction?
What can BIS do based on a criminal conviction?
What is the purpose of the 180-day deadline mentioned in the text?
What is the purpose of the 180-day deadline mentioned in the text?
What is the consequence if the disclosing person fails to meet the 180-day deadline or an extended deadline?
What is the consequence if the disclosing person fails to meet the 180-day deadline or an extended deadline?
What information must be included in the complete narrative account mentioned in the text?
What information must be included in the complete narrative account mentioned in the text?
Under what conditions may the Director of OEE grant an extension to the 180-day deadline?
Under what conditions may the Director of OEE grant an extension to the 180-day deadline?
What information should a request to extend the 180-day deadline include?
What information should a request to extend the 180-day deadline include?
What is the purpose of the toll the statute of limitations provision mentioned in the text?
What is the purpose of the toll the statute of limitations provision mentioned in the text?
What is the purpose of the interim remedial compliance measures that the Director of OEE may require as a condition of an extension?
What is the purpose of the interim remedial compliance measures that the Director of OEE may require as a condition of an extension?
What is the significance of the statement that the disclosure will be deemed to have been made on the initial notification date if the narrative account is submitted within the deadline?
What is the significance of the statement that the disclosure will be deemed to have been made on the initial notification date if the narrative account is submitted within the deadline?
What is the significance of the statement that the 180-day deadline is an initial deadline?
What is the significance of the statement that the 180-day deadline is an initial deadline?
What is the primary purpose of the provisions in the text regarding the Director of OEE's authority to grant deadline extensions?
What is the primary purpose of the provisions in the text regarding the Director of OEE's authority to grant deadline extensions?