Export Control Blog

Export, etc. 1/20/06

• SITAC sitdown a week from Tuesday
• Ryan Zelnio of The Space Review tackles export controls on commercial satellites and other space technologies (Part One, Part Two)
• US sanctions Syrian military intelligence chief (Treasury press release here). Blocking Assef Shakat's assets is one thing, but whatever you do don't crack jokes about his wife.
• OFAC relents, allows Cubans to play in World Baseball Classic (and with a turnaround time of four weeks since the league's reapplication sets what must surely be a record of its own)
• Across-the-board mandatory AES delayed yet again
• Iran moving assets out of Europe in anticipation of sanctions threat
• Seoul providing Pyongyang with "strategic" communications gear
• Boeing CIO: ITAR is a "a big deal for us"
   

Reading This Post Is Mandatory

Question: What do you think might happen if a government agency blasted their mailing list of corporate compliance types with notice that they "need to attend" a "mandatory" conference (which, by the way, isn't the least bit compulsory)?

Answer: Don't ask me, ask the Census Bureau, who set off a mild panic earlier this week with this an email broadcast which started like this:

Mandatory AES Compliance Conference: Seminars $199/Person

If you are currently exporting or even plan to export in the future you need to attend this new Mandatory AES Compliance Conference. Experts from the U.S. Government will teach you about the new export regulations and the stiffer penalties of up to $10,000 per non-compliant transaction.  Let us help you get it right the first time and avoid unwanted and costly encounters with government enforcement agencies.

I'm no grammar expert (try him), but this is ambiguous enough that it doesn't seem so crazy that some folks might not be sure whether the adjective "mandatory" is supposed to modify "AES" or "Compliance Conference". (Hey! You snot-nosed kids in the front -- quit your snickering. Sure, those of us who've been closely following the slow transition from paper Shipper's Export Declarations to the Automated Export System probably figured this out right away. But let's remember that not everyone can follow every development in the world of exporting quite so obsessively.)

So, no you are not obliged to pay the government $199 so you can dedicate nine and a half hours of your life listening to them explain what you could almost certainly figure out for yourself in twenty minutes by reading this FAQ. AES will indeed soon be mandatory (it already is for items on the CCL or USML), but these Census conferences are not. Which is just as well since the nearest one to me is in Detroit. (Clevelanders poke fun at Detroit. Not sure who those in Detroit ridicule...Windsor?)

The missive from Census pointed recipients to a website with similarly confusing language. Someone in the Foreign Trade Division must have figured out how confusing this all was because they edited the site, but they couldn't edit Google's cache, which I've reproduced below for posterity's sake (click to enlarge).