Past event: EAR / OFAC Export Controls e-Seminar

John Black
Principal - BSG Consulting

John R. Black has been involved in US export and trade control matters since 1984. He advises a wide range of US and foreign companies, ranging in size from Fortune 10 to small companies in nearly every industrial sector. He also serves as an expert export control adviser to several major US law firms and their clients, and has advised several foreign governments on US export control matters. Within the export compliance field, he has earned a reputation as one of the leading experts on US export and trade controls.

From 1984 through 1988 he worked for the Bureau of Export Administration, where he was responsible for writing the Export Administration Regulations (EAR) and interpreting the EAR for government and industry. From 1988 to the present, Mr. Black has been an export/trade control compliance consultant.

Mr. Black has developed a comprehensive knowledge of the Export Administration Regulations (including the antiboycott provisions), the International Traffic in Arms Regulations, and the trade control regulations administered by the Office of Foreign Assets Control. He uses his depth of expertise in multiple US trade control regulations to help his clients ensure they comply with the entire scope of US trade controls.

Mr. Black has advised major US exporters on export control internal compliance policies, processes, and procedures. He has also conducted many export control compliance audits for his clients and worked with them to implement remedial measures to address deficiencies found in the audits. Mr. Black has worked with companies involved in export enforcement actions and has helped them to develop comprehensive remedial compliance policies, processes, and procedures which have successfully mitigated the penalties imposed for their violations.

Mr. Black’s comprehensive knowledge of US regulations and his understanding of practical business requirements enable him to develop targeted in-house training programs for US and foreign companies. He has been a featured speaker at well over 100 conferences and seminars on US export controls throughout the United States, Europe, and Asia. He has also written numerous articles for various legal and export publications regarding US export/trade controls and has written several books on the subject.


Scott Gearity
Principal - BSG Consulting

Scott Gearity is a Principal of BSG Consulting, bringing over 15 years of consulting, training and corporate export compliance program management experience to bear for his clients.

Mr. Gearity has substantial experience in military, dual-use and commercial export controls. His clients have ranged in size from small start-ups to some of the world’s largest companies, with a particular focus on the information technology, telecommunications, networking and software industries.

Mr. Gearity joined BSG from Microsoft Corporation, where he was based in Ireland and managed the company's export compliance program for Europe, the Middle East and Africa. He continues to advise many non-US companies affected by US export controls.

Mr. Gearity holds a Bachelor of Arts degree in international studies and economics from American University. He is a licensed US customs broker.


Felice Laird
Senior Consultant

Felice Laird has over twenty years' experience helping companies comply with the US Export Administration and International Traffic in Arms Regulations.   Felice specializes in transactional work, reviewing clients' product lines to establish licensing requirements and then providing guidance on how best to deal with any government restrictions on export.  Felice is a subject matter expert in encryption export controls and has helped both large and small firms navigate the complex restrictions on data security technologies.

Prior to becoming a consultant, Felice worked at the Department of Commerce in what is now the Bureau of Industry and Security.  She also worked as an International Trade Analyst at the law firm of Paul, Weiss, Rifkind, Wharton and Garrison and as an Export Compliance Administrator for GTE Corp (now Verizon).  

Felice served on the encryption working group of the President’s Export Council Subcommittee on Export Administration (PECSEA), as well as serving as a PECSEA member during the Bush Administration.  Felice is active in the National Council on International Trade and Development and TechAmerica’s Export Committee.  She has a BA from the University of New Hampshire and a MS in International Business from the American University.

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EAR Export Controls e-Seminar Modules

1. Introduction to Export Controls

• US Export Control Policy
• Primary US Export Regulations (EAR/ITAR/OFAC)

2. Controlled Items & Activities

• What is Subject to Controls?
• Export Control Regulated Activities

3. Jurisdiction & Classifications

• Jurisdiction:  Which List Applies?
• (CCL/NEML/USML)
• How Do I Classify an Item?
• Determining the ECCN
• Requesting an Official Classification

4. NLR (No License Required)

• NLR Determination

5. License Exceptions

• ECCN-based License Exceptions
• Other Useful License Exceptions

6. Catch All Controls

• Prohibited Parties/Embargoed Countries/Proliferation Activities
• Red Flags
• China Military End Use
• EAR General Prohibitions

7. License Applications

• When Do I Apply for a License?
• Making an Application to BIS
• SNAP-R / Electronic Filing
• License Review Process

8. Administration, Documentation & Shipping

• Foreign Trade Regulations (FTR)
• Automated Export System (AES)
• Harmonized Tariff Schedule & Schedule B
• Export Documents
• Customs & Border Protection

9. Reexports:  US Controls on Overseas Activities

• General Guidelines
• Who is Responsible?
• Foreign-made Items Incorporating US Parts
• Foreign-made Items Incorporating US Technology

10. Technical Data & Software

• "Publicly Available Information"
• Deemed Exports to Foreign Nationals
• Internet Exports
• Relevant License Exceptions
• Cloud Computing:  Who is the Exporter?

11. Internal Control Programs

• Effective Compliance Plans
• Resources:  Where Can I Go for Help?
• Export Management & Compliance Program "Core Elements" (BIS)
• Areas of Frequent Compliance Breakdown

12. US Embargo Controls

• Embargoed Country Destinations
• Transactions Subject to Embargo Controls

13. Export Enforcement

• What is the Office of Export Enforcement?
• When "Enforcement" Comes Knocking...
• Enforcement Case Studies
• Preventing and Coping With Violations

14. Information Technology & Encryption

• Computers, Telecom & Software Controls
• Encryption Controls

15. Aerospace Issues

• Aerospace Export Classification
• Special Considerations for Aerospace

16. Antiboycott

• 6 Prohibitions of Antiboycott Regulations
• General Antiboycott Guidelines

17. Export Control Reform (ECR)

• How to read and understand the new approach to US Munitions List categories
• Revised and new USML categories
• New 600 series ECCNs from items shifted off the USML
• New licensing requirements for items shifted off the USML to the 600 series
• How the current ‘items specially designed for items on the USML’ approach will be replaced with multi-level and lengthy USML controls
• USML’s use of the new “specially designed” to transfer many items to the CCL
• Much, much more