US (re-)export control law asserts extraterritorial jurisdiction, meaning that exports occurring outside the United States may also be subject to US export control regulations. This can apply, for example, when exporting goods of US origin, goods containing US components, involving a US person in the export process, or when supplying certain customers or countries subject to a US trade embargo. As a result, US export controls impact EU and third-country companies. Sanctions imposed by the US administration for violations of US (re-)export control laws can be severe. Notably, US authorities can place a company on a sanctions list, preventing other businesses from engaging in trade with that company. This effectively cuts the listed company off from the US market. Consequently, EU and third-country companies must be aware of US export control requirements and incorporate 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