(CUSECO) Requirements
Certified U.S. Export Compliance Officer® – Knowledge Requirements:
The following topics are defined as within this body of knowledge and are reflected in the knowledge assessment requirements stated for this certification. A person holding this certification will have satisfactorily passed an examination that demonstrates a high degree of knowledge of these topics and knowledge requirements. Score 75% or higher on examination.
Continuing Education Requirement: The IIEI Certification Advisory Board has set the further requirement that before an individual reaches their expiration date, all Certified U.S. Export Compliance Officers® must have completed 10 Continuing Education Units (CEUs) each year to maintain certification.
Industry Standard: (1) Demonstrate current knowledge and usage of US export compliance regulations, concepts and processes. (2) Demonstrate in-depth knowledge of export documentation for EAR, ITAR and other regulations for goods requiring a validated license. (3) Demonstrate an understanding of the industry’s professional code of ethics:
| Topic: EAR – Export Administration Regulations | Knowledge Demonstrated |
| Role of the Bureau of Industry and Security (BIS) | To have an understanding of the duties and responsibilities of the BIS and its legal authority. |
| Scope of the Export Administration Regulations (EAR) | To gain appreciation and understanding of scope of activities the EAR. |
| EAR Control Lists | To possess a working knowledge of the various EAR control lists. |
| EAR License Exceptions | To know the exceptions to BIS license requirements. |
| EAR Special Reporting Requirements | To possess a working knowledge of the various EAR special reporting requirements set forth by the BIS. |
| Embargoes and Special Controls | To know the general underlying reasons for BIS embargoes and special controls used for enforcement. |
| EAR License Application Processing and Issuance | To understand the application process for shipments that requires an EAR license. |
| EAR Export Clearance Requirements | To know and appreciate the EAR clearance requirements and procedures. |
| Restrictive Trade Practices and Boycotts | To know the common trade restrictive practices. |
| EAR Record Keeping | To have a working knowledge of all forms used by the BIS in maintaining compliance with the EAR. |
| EAR Terms and Definitions | To know the common terms used in the BIS to communicate and enforce EAR policy. |
| EAR Forms | To know the major EAR forms and their usage. |
| Bureau of Industry and Security web site | To know how to navigate the BIS’s web site to find updated control lists. To be able to subscribe to the BIS’s e-mail update service. |
| Topic: ITAR – International Traffic in Arms Regulations | Knowledge Demonstrated |
| Introduction and Overview of ITAR | To understand the history, purpose and reasons why ITAR exists. To form a basic understanding of how ITAR regulations are organized and enforced internationally. |
| Section 38 – Arms Export Control Act 22 USC 2778 | To know how and why ITAR was created. |
| Export Control Concepts | To understand the full range of concepts and issues regulated by ITAR. |
| Industry Responsibility and National Security | To know and gain an appreciation of the responsibilities and knowledge requirements of the export compliance officer. |
| Government Agency Roles | To understand the roles of the various government departments and agencies such as the State Department, Commerce Department, Office of Foreign Asset Control and other significant departments and agencies such as Treasury Department, Customs Department and the Food and Drug Administration. |
| ITAR CFR Sections 120 – 130 | To posses a working understanding of the ITAR regulations and specifically focus on defense, national security, dangerous drugs, endangered plans and radioactive materials. |
| Compliance Issues including Dual Use Items | To be able to identify dual use items. To gain an appreciation of the issues related to ITAR compliance. |
| ITAR Amendments | How to remain current with ITAR amendments and rulings. |
| Researching ITAR topics with the Federal Register and other Resources | Understand how to research ITAR issues using various the Federal Register and various resources. |
| ITAR Documents | Understand and demonstrate how to apply for an Export License. Filings (process, rules, regulations, exceptions and involved parties) To posses a working knowledge of the documents and paperwork required to maintain ITAR compliance. |
| Personal and Business Liability (issues and practices) | To understand how to minimize both company and personal liability with respect to ITAR compliance. Real-life scenarios of compliance related situations. To gain an appreciation for the real-life problems related to ITAR compliance. |
| Topic: Documentation for US export compliance | Knowledge Demonstrated |
| EAR and ITAR Regulatory Overview | To understand the history, purpose and reasons why ITAR exists. To form a basic understanding of how ITAR regulations are organized and enforced internationally. |
| Agency documentation Requirements | To gain familiarity with EAR, ITAR and US Treasury documentation requirements. |
| Common Export Documents used for compliance | To understand the usage of the most common documents used in export compliance. |
| Departmental Documentation forms and usage | To understand the usage of other State Department, Treasury Department (e.g., ATF, OFAC) and Commerce Department documents: |
| General Red Flags | To recognize red flag issues. |
| Special Nuclear Regulatory Requirements | To know the NRC requirements |
| Shipment Marking Requirements for Export Compliance | To know the special marking requirements for export compliance. |
| Special Certificate Requirements | To know the special certificate requirements. |
| Knowing your Source of Supply | To know the due diligence requirements for trade compliance. |
| Topic: Ethics in Trade Compliance | Knowledge Demonstrated |
| Define Ethics | To differentiate between morals and ethics.
To identify and assess ethical issues. |
| Traditional View of Ethics | To comprehend how individuals establish their ethical values.
To know how ethics and the law relate to one another To identify the forces the shape personal ethics. |
| Impact of Ethics on a Company | To demonstrate an understanding of forces within a company that shapes its ethical actions. |
| Compliance Environment | To know the reasons why compliance regulations and ethical actions clash. |
| Ethical Situations in Compliance | To critically evaluate the forces in the business environment that cause ethical dilemmas in compliance.
Identify the possible participants that can cause an ethical issue to exist. |
| New Ethical Standards | To demonstrate knowledge and appreciation for the challenges of establishing new ethical or compliance standards. |
| Resistance to Change | To analyze and assess the relationship and function of the various existing formal and informal policies (or lack of them) that supports the organization’s current ethical actions.
To understand why ethical practices should remain constant over time. |
| Establishing an Ethical Stance | To be able to determine and design an individual ethical position that supports a compliant organization within the context of the letter and the spirit of the law. |
| Monitoring and Control of Ethical Compliance | To know the importance of all employee’s actions to support the compliance effort.
To assess the actions of individuals in the workplace as they relate to trade compliance. To understanding the basic methods used to control ethical actions in the compliance workplace. |
| Knowledge Source: | Export Administration Regulations. 15 C.F.R. 730-774 (current version) US Department of Commerce Bureau of Industry and Security, US Government Printing Office
Supplements to Export Administration Regulations. (current version) US Department of Commerce Bureau of Industry and Security, US Government Printing Office Ruling addendum to Export Administration Regulations. (current version) US Department of Commerce Bureau of Industry and Security, US Government Printing Office International Traffic in Arms Regulations 22 C.F.R. 120 – 130 - ITAR Regulations of the US (current version) , US Government Printing Office Section 38 – Arms Export Control Act 22 USC 2778 , US Government Printing Office
8 USC 1101, 8 USC 1324, 22 USC 2778, 22 USC 2794 22 CFR 120-130, 31 CFR 500-599 15 CFR 300-799 |