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Comtech EF Data Corporation Export Compliance

As one of the leading manufacturers of digital and RF Products, including data modems, low noise amplifiers, solid state amplifiers, RF up and down converters, redundancy subsystems and complete data TX/RX terminals, for the satellite communications industry, Comtech EF Data Corporation (the Company) takes its position as market leader and corporate citizen with the utmost seriousness. Recognizing that the illegal diversion of high technology commodities and technical data to military, terrorist, or nuclear/missile/chemical weapons proliferation activities poses a serious risk to the national security of the United States, as well as other nations in which the Company does business, and since export control regulations apply to virtually every aspect of our business, the Company has and will maintain a strict export control policy.

 

Jurisdiction

Comtech EF Data products have been reviewed and classified by the U.S. Department of Commerce (DOC) and are subject to the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security (BIS). The EAR can be reviewed at the following web address: http://www.bis.doc.gov/

 

Export Classification Control Number (ECCN)

ECCNS Model Numbers View a complete listing of ECCNs by model number

 

Export Control Statement

Each sales order acknowledgement and commercial invoice contains the following statement:
THESE COMMODITIES, TECHNOLOGY OR SOFTWARE WERE SHIPPED DOMESTICALLY AND/OR EXPORTED FROM THE UNITED STATES OF AMERICA IN ACCORDANCE WITH THE EXPORT ADMINISTRATION REGULATIONS. DIVERSION CONTRARY TO U.S.A. LAW IS PROHIBITED.

 

Schedule B Numbers for Export/Harmonized Tariff System Numbers for Import

Product Schedule B HTS
Digital (Modems, Switches, etc.) and
RF Products (Converters, LNAs, Transceivers, etc.)
8517.62.0050 8517.62.0050
Warranty Returns/Repairs 9801.10.0000 9801.10.0000

 

Customer Purchase Order Requirements

All customer purchase orders must include the following:

  • Bill to Name and Address
  • Ship to Name and Address
  • Country of Ultimate Destination
  • End User Name and Address

 

End User Statements

Customer Purchase Orders are subject to an End User Statement request for certain exports based on the following criteria:

  • New Customers
  • Export Restrictions on the Equipment (ECCN restrictions)
  • Ship to Address to a Freight Forwarder or Warehouse
  • Destination to Countries with known Diversion Risk
  • Red Flag Indicators

 

Restricted Party Screening

Purchase Orders are subject to Restricted Party Screening (RPS) of Customers, Contacts, Freight Forwarders, Third Party Vendors, etc. RPS is done using dynamic screening software that checks many U.S. Government regulated list such as:

  • Denied Parties – DOC (BIS)
  • Special Designated Nationals (SDN) – U.S. Department of Treasury (OFAC)
  • Entity List – DOC (BIS)
  • Unverified List – DOC (BIS)
  • Debarred List – Department of State (DOS)

Results of the screening may trigger an End User Statement request or Export Licensing requirement.

 

Export Documentation

All Exports from the USA require a Commercial Invoice. Comtech EF Data will not release shipments to freight forwarders or carriers without a Comtech EF Data commercial invoice or a Customer Supplied invoice for a drop ship request. All invoices other than CEFD will need to be reviewed and approved by the logistics department.

 

Prohibitions

Embargoed/Sanctioned Nations – The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) maintains the listing of nations under embargo or sanction of U.S. goods. Comtech EF Data products are prohibited from shipping to the following countries:

  • Cuba
  • Iran
  • North Korea
  • Sudan
  • Syria

Please refer to the OFAC web address for additional details: http://www.ustreas.gov/offices/enforcement/ofac/programs/

 

General End Use Prohibitions

The U.S. Government places export controls on certain nations principally due to national security. In addition, the Export Administration Regulations places limits on products being used in some of the following activities:

  • Missile technology
  • Foreign military applications
  • Nuclear proliferation
  • Terrorism, etc.

Please refer to EAR Part 736 for more details at web address: http://www.access.gpo.gov/bis/ear/ear_data.html

 

U.S. Foreign Corrupt Practices Act (FCPA)

The FCPA is a U.S. statute that prohibits U.S. companies and their representaties from giving, paying, promising, offering, or authorizing the payment, directly or indirectly through a third party, of anything of value to any Non-U.S. “foreign official” to persuade that official to help the company obtain or keep business or to secure some other improper advantage.

More Info »

 

Violations

Comtech EF Data Export Controls Group will report any known violations to the appropriate government agencies: DOC Office of Export Enforcement (OEE), Department of Homeland Security – U.S. Customs and Border Protection (CBP), or U.S. Department of State.

 

Questions/Contacts

Comtech EF Data Export Controls Group is available for questions or concerns:

Cheryl Crow – Director, Logistics/Trade Compliance Official
Phone: +1.480.333.2187
Fax: +1.480.333.2470
Email: ccrow@comtechefdata.com

Lexa Jones- Sr Security Manager/Trade Compliance Official
Phone: +1.480.333.2157
Fax: +1.480.333.2470
Email: ljones@comtechefdata.com

Richard Estrada – Export Coordinator
Phone: +1.480.333.2332
Fax: +1.480.333.2470
Email: restrada@comtechefdata.com