US (re-)export control law claims a so-called extraterritorial application. This means that exports that take place outside the USA can also be subject to US export control regulations. This may be the case, among other things, when goods of US origin or goods with US components are exported, a US person is involved in the export or when certain customers and countries are supplied, against which the US has imposed a trade embargo. The US export controls therefore affects EU and third-country companies. The US administration's sanctions for violating US (re-)export control laws can be severe. In particular, it should be noted that the US authorities can place a company on a sanctions list, with the result that other companies are no longer allowed to do business with this listed company. The practical consequence of this measure is that the company will be cut off from trading with the US market. EU and third-country companies should therefore also be aware of US export control requirements and integrate them into their export compliance processes.
Understand the conditions under which a EU or third-country company and its export business is subject to the requirements of US (re-)export controls.
• Concept of extraterritoriality of US export controls
• Definition of US goods & the so-called de minimis rule
• Definition of US person
• Concept of US embargoes
• Scope of the so-called Secondary Sanctions
Management board, heads of departments, export control officers and export employees of EU and third-country companies