Export Compliance Program (ECP)

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1. Statement of commitment

[Company Name] is committed to full compliance with US export control laws, including the Export Administration Regulations (EAR, 15 CFR 730–774) administered by BIS, and — where applicable — the International Traffic in Arms Regulations (ITAR, 22 CFR 120–130) administered by DDTC.

2. Scope

This ECP applies to all [Company Name] employees, contractors and agents worldwide, and to all transactions involving items, technology, software or services subject to US jurisdiction.

3. Roles

Empowered Official / Export Compliance Officer: [Export Compliance Officer].

Senior Management Sponsor: [Company Owner].

Functional leads: Engineering, Sales, HR, IT — each accountable for screening and recordkeeping in their domain.

4. Jurisdiction and classification

All products, software and technology are classified by ECCN (EAR) or USML category (ITAR) before any cross-border activity. Classification decisions are recorded in the [Company Name] Classification Register and reviewed when a product changes materially.

5. Restricted party screening

All counterparties (customers, end-users, suppliers, distributors, partners, employees, visitors) are screened against the consolidated US lists (DPL, Entity List, Unverified List, MEU List, SDN List) and equivalent EU/UK lists prior to engagement and re-screened periodically.

6. Licensing

No controlled export, re-export, transfer or deemed export takes place without confirmation of license requirements. License applications are submitted by the Export Compliance Officer; License Exceptions are used only where conditions are documented and met.

7. Deemed exports

Release of controlled technology or source code to foreign nationals inside the US is treated as an export. HR, IT and hiring managers coordinate with the Export Compliance Officer before granting access.

8. Recordkeeping

All export records (transactions, classifications, screenings, license decisions, end-use certificates, training) are retained for at least 5 years from the date of the transaction.

9. Training

All in-scope personnel receive role-based export training on induction and at least annually thereafter.

10. Audit and reporting violations

The Export Compliance Officer conducts an internal audit at least annually. Suspected violations are reported immediately to [Company Owner]; voluntary self-disclosures to BIS / DDTC are evaluated case-by-case with external counsel.

Approved by: [Company Owner] Effective date: [Effective Date] Next review: [Review Date]