Does your company source components or parts outside the U.S.? When doing so, you need to be careful about sending unlicensed export controlled technical data like drawings, blueprints and manufacturing instructions as part of an RFQ or production process. Many companies send such information to overseas parts vendors and to non-U.S. person employees at domestic vendors without a systematic check to see if the information requires an export license. And an increasing number of companies already have — or are establishing — offshore engineering centers of their own, or they have a relationship with an offshore third party engineering center, without focusing on the need to implement a rigorous process to ensure that data exchanged with those centers is licensed for export when needed. Similar challenges arise when engineers and procurement personnel at U.S.-based business units collaborate with a sister facility abroad, or they use web-based collaborative platforms (e.g. Sharepoint) for product development without thinking through export control concerns.
Yes, technical data export issues are more difficult to address in the same systematic way that product export issues are handled. Decision making about what data is shared and how it is shared (email, express mail, uploading to…
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