FTS-DOC ITA

Moderator: Linda Abbruzzese

July 16, 2009

3:00 pm CT

Coordinator: Welcome and thank you for standing by. At this time all participants are in a listen-only mode until the question and answer session of today’s conference. At that time you may press star 1 on your touchtone phone to ask a question.

I would also like to remind parties that this call is being recorded, if you have any objections please disconnect at this time. I would now like to turn the call over to Miss Linda Abbruzzese. Thank you, you may begin.

Linda Abbruzzese: Thank you and good afternoon for those of you joining on the East and West Coast. Thank you for joining us for our Webinar from the Bureau of Industry and Security on the special comprehensive license. I am pleased to note that we have more than 56 people registered for this Webinar today and currently we have 46 who are participating.

I am Linda Abbruzzese. I am the International Trade Specialist for the Marketing and Communications Office for the US Commercial Services at the Department of Commerce. This Webinar is being brought to you in cooperation by the US Commercial Service and the Bureau of Industry and Security. And I would like to welcome all participants in the export community who are joining us from all across the United States to learn about the special comprehensive license.

In a moment I'll turn this presentation over to Angela Robinson, Export Administration Specialist of the Office of Exporter Services for the Bureau of Industry and Security and (Regenita Carol), Export Compliance Specialist of the Office of Management and Compliance Division for the Bureau of Industry and Security. Both presenters will be available at the end of the presentation to answer your questions and contact information will also be provided.

Now for those of you who just logged on you can still listen via the Internet and also you can listen per the audio passcode and instructions that were sent to you by email.

We do have a few housekeeping details to make sure everyone gets the most benefit from this afternoon’s Webinar. You will be able to hear this presentation via your telephone and you can view it simultaneously via your computer. So if you are not hooked up through both please take a moment to do this.

If you are experiencing any technical difficulties during this presentation please press star 0 anytime during the presentation. In this Webinar we will be taking written and voice questions at the end. To ask a written question we invite you type in your questions via the Q&A icon on the left hand side of your screen on the very top of your computer and screen there is an icon with the letters Q&A.

If you move your cursor to that icon you will be able to write in your typed questions. We will compile these questions and present them during our presentation. And any typed questions which we will not be able to answer we will help you out and give you a personal answer via email after the Webinar.

At the end of this presentation we will also be taking voice questions. To ask a voice question please press star 1 on your telephone. Now for those of you who would like a copy of the PowerPoint presentation slides there is an icon on the upper right hand side of your computer that looks like there are three pieces of paper on top of one another.

The icon is right next to a yellow looks like notepad icon. If you place your cursor over the white three pieces of paper you will be able to download the PowerPoint presentation slides onto your desktop or onto your folder.

Now for those of you who just joined us you can still log into our Internet conference. And now I'd like to introduce Live Online Angela Robinson who is our Export Administration Specialist of the Office of Exporter Services for the Bureau of Industry and Security. Angela, thank you for joining us.

Angela Robinson: Good afternoon. As Linda said my name is Angela Robinson. I'm an Export Specialist with the Regional Education Services Division of the Bureau of Industry and Security. We generally provide guidance to the export as well as the export community regarding export licensing requirements. And we help in identifying the ECCN, Export Control Classification Numbers for items being exported.

The special comprehensive license or SEL is one of those specialized bits of guidance we provide for exporters involved with multiple transactions to the same customer. At this time I would like to introduce Miss (Regenita Carol), she’s an Export Administration Specialist with the Office of Management and Compliance Division.

(Regenita Carol): Good afternoon. This is (Regenita Carol). I'm hear to talk to you about the special comprehensive license. We’re going to refer to it as the SCL, and that can be found in Part 752 of the Export Administration Regulations.

Now as Linda said if we run out of time you can call me or one to the SCL staff and we will be glad to answer any questions you have.

Now today’s topics, number one, what is an SCL? What activities are covered under an SCL? What items are covered under the SCL? What countries are eligible for an SCL? Steps to take in applying for an SCL. The application process and the internal control program, we’re going to refer to that as the ICP.

Okay, what is an SCL? A special comprehensive license. An SCL is a licensing mechanism that may be used instead of repeating the submission of individual license applications. The SCL can cover multiple exports and re-exports of items subject to the Export Administration regulations.

Now this is not a shortcut to avoid licensing requirements. An SCL is a little more complex and time consuming than applying for several licenses. But once you have been approved it becomes very easy.

An SCL is not for everyone. If you use an SCL you can save time and paperwork for it allows unlimited quantities of certain goods to approved consignees in almost all countries without needing an export license for each order. Now this cuts your paperwork and expedites your overseas shipments.

Now the SCL is a privilege, it’s reserved for companies with a solid licensing history and internal control program, and the ability and corporate commitment to implement certain screening responsibilities for the SCL holder and the SCL consignees.

Now this is through the use of an internal control program so we’re going to go over the ICP a little later on in the presentation. The SCL will authorize specific exports and re-exports that are otherwise prohibited under an individual license.

Now the SCL holder and the SCL consignees are expected to know their customers and to establish a solid relationship with the recipients who receive goods under the SCL. The corporate management is expected to be directly involved in assuring compliance with and maintaining the quality of the ICP.

Management must ensure training, reviews, screen checks and communication throughout the company that extends to its consignee. Now because (BIF) does not review each individual transaction parties to the SCL must ensure that each export and re-export made under the SCL meets the terms and conditions that are made under the SCL.

Now the SCL is definitely more flexible than an individual license. Let me give you a few benefits of having an SCL. Amending the license instead of having to maintain multiple licenses. You can ship to multiple consignees and end users.

You have the option of direct shipment between the license holder and end users or the direct shipment between consignees and end users. The SCL is valid for a four-year period with the possibility of renewal for another four years.

Okay what activities are covered under an SCL? Now under the SCL you may export and re-export items subject to the EAR to perform various activities including but not limited to spare and replacement parts for servicing and/or stocking, items for use as capital equipment, items for sale and/or resale by designated SCL consignees and other activities will be considered on a case by case basis.

What items are allowed under an SCL? This can be found in Section 752.2 of the EAR. Now all items subject to the EAR are allowed under an SCL. Items subject to the EAR means commodities, software, technology and activities under the jurisdiction of the BIS in Part 734 of the EAR.

These items are considered dual use items, items that have both commercial and military uses. The SCL is purely for commercial items. There are certain items for which you cannot apply for an SCL and some of the items are, items controlled for missile tech reasons that are identified by the letters (MC) on the classification list, certain ECCNs controlled for chemical or biological reasons, certain items used in the production of chemical weapons precursors and chemical warfare agents to certain destinations.

Items controlled for short supply, items controlled for encryption, maritime civil nuclear propulsion systems, certain communication devices, technology of the development production or overhaul of commercial aircraft engines.

The BIS may identify items that are not listed in this category as ineligible. Items controlled for nuclear nonproliferation reasons are authorized on a case by case basis. Now Part 752.3 will go in more detail and have the specific ECCNs that are not eligible.

What countries are eligible for an SCL? Now all countries are eligible under an SCL except Cuba, Iran, Iraq, North Korea, Sudan, Syria and other countries BIS may designate on a case by case basis. Now also under an SCL one cannot service any items if you know the item is owned or controlled by or under the lease or charter of the above countries or any national of that country.

Steps to take to apply for an SCL. Now first you must contact the Export Administration Compliance Division director and describe your licensing scenario and he will determine if you meet the SCL criteria. If yes then a pre-consultation meeting will be set up. Now this can be a face to face meeting or held by telephone.

If it is determined that a pre-consultation is not needed and enough information has been received a pre-consultation package - application package will be mailed out to you. You use the same license documents as the individual license, the 748P multipurpose application, you check SCL, the BIS 748P-A item appendix, the BIS 748P-B end user appendix and the BIS 752 statement by consignee in support of the SCL. This should be completed by the consignee.

The BIS 752-A re-export territories and all applicable certification that is required. And also the ICP and a comprehensive narrative on your company letterhead. Once this is completed mail to the director. And when we receive it a compliance specialist will review your internal control program portion and a licensing officer will review the license application.

The SCL licensing documents do not go into SNAP-R. Documents must be mailed to the US Department of Commerce, 14th and Pennsylvania Avenue NW, Room 2099, Washington DC 20230 at the attention of the (ENC) Director.

Okay the application review process. We look at prospective SCL holders, the past licensing history and projected exports, the applicant’s history of compliance with the EAR, now this will give us an idea of what the company was doing prior to requesting an SCL.

We take a look at the company’s export and re-export documents to ensure compliance. We talk to the company officials, now this may be included in your pre-consultation meeting, we may even want to talk to the official at the consignee location.

When we talk to company officials and staff members we can get a feel of their commitment towards export compliance. Now the company’s commitment to maintaining an adequate ICP, the pre-consultation meeting will narrow down what elements will be included in your ICP.

Okay now let’s go over the internal control program which is a mandatory requirement to being accepted in the SCL. The SCL holder and the consignee must maintain an ICP. Now this, like I said, to quality for an SCL you must develop this.

The elements of your ICP will reflect the complexity of the activities authorized under the SCL, the countries and items involved and the relationship between the SCL holder an the approved consignees.

Some of the elements may be waived by BIS. During your pre-consultation if it is determined there is no need for certain screen checks it will be documented and waived by the director.

Elements of an ICP. Basically there are about 17 elements in the ICP guidelines. I will briefly go through them all. As mentioned before some could be waived and some can even be merged together.

Number one, management oversight and corporate commitment. Now the company must show and describe how it will be committed to ensure compliance with the export regulations. Upper management must design a corporate policy statement that reflects the commitment of the company and issue it to all employees, the contractors, agents and anyone that is involved in exports.

Number two, identification of personnel and responsibilities. A chart or list the employees with export-related duties should be developed. Now this will show and describe the key contacts for positions and who does what, include their phone numbers and email address. That includes personnel at the license-holder location and the consignee location.

Number three, communication requirements with the distribution and acknowledgement of license and regulatory information. You must communicate regulatory information to your staff. Now there would be procedures to distribute regulatory information and license changes to the US staff and the consignee's.

An effective partnership between the license holder an the consignee must be established through verifiable methods of communication of information. Now there should be a timeframe for distribution and acknowledgement to ensure the materials that is distributed and acknowledged within a reasonable timeframe and is sure receipt of information.

Your critical information should have a different acknowledgement timeframe than regular information you distribute. Have procedures in place if you do not receive an acknowledgement, you can send out another notification.

Number four, the denied persons screen. Now you must establish procedures to screen against the (DPL). Document all your screening transactions, keep a paper trail as proof of screening. Now this screen can be combined with your other screen checks and we'll talk about that a little later.

Number five, items and country compliance screen. Establish procedures to screen your items and countries. This can be manual screen or automated.

Number six, compliance reviews. You must have procedures in place to conduct your audits or reviews on your consignees and customers and even at the license-holder’s location. This will help to ensure that compliance is being exercised with the EAR and license conditions.

You decide on who will conduct the review. It can be an outside person or an internal staff member. Develop an audit module to cover the critical topics. Document the review. Now BIS has created an audit module that can be tailored to fit your company. It is recommended that a review or audit be conducted at least annually.

You may even want to have your consignee complete a self-assessment module or checklist through the year or years that an audit has not been conducted.

Number seven, the nuclear end-use screen. Now this screen will help ensure that the SCL will not be used to export or re-export to any restricted end uses. You can conduct this screen check when you perform the other proliferation screen checks that we’re going to talk about.

Number eight, record keeping. Now a program for recordkeeping is required by Section 762 of the EAR. Keep documents of your export records and transactions for five years from the date of export from the US. You can list these records in a chart format and identify who keeps the record. It could be one central location or specific individuals.

Number nine, the transaction flow screens is your order processing. Establish an internal process to describe your transaction flow. Start at the beginning of an order, include where the screen checks take place, where the hold function is incase there are questions regarding a transaction. And show where the shipment documents are verified to ensure the proper information is on the documents until the shipment goes out.

Then number 10, I want to ask you to change this to your training element. This was a oversight so we’re going to talk about training on number 10 and scratch high-risk shipment requirements. Okay your training program, now this is a critical element, ongoing training will ensure employees are kept abreast of export laws and changes.

There should be cross-training of positions. Have a backup person in place. At a minimum there should be annual training. If you have a small company with a few people there should be, you know, exchange of information such as memo, verbal communication and service training.

You can set up training on the computer for your staff. At the end of the session there can be a test that they have to pass. Now this will serve as certification and, you know, print out the certification and keep as proof that the class has been taken.

Number 11, notification of noncompliance. Now have procedures established for employees to notify management if there are questions regarding a transaction or any signs of noncompliance. There should be procedures to notify BIS if there has been a violation or any other government agency that may be involved.

Now number 12-17, diversion risk red flag screen, rocket system and unmanned air vehicle in-use screen, the chemical and biological end-use screen, the anti-boycott screen, the entity list screen and the special designated global terrorist screen, now these checks all must be done if it decided by the director at the pre-consultation.

But the good news is BIS has developed a checklist for all these screens. So the checklist basically will walk you through a series of questions to determine if you can do business with the customer.

Now these checks are recommended to be done at the beginning of an order and then annually to ensure that there are no major changes to the companies business.

Okay, EMCD services, these are other services that we provide. As you can see we do compliance guidance, best practices, we provide free compliance advice that could be - come through a fax, a telephone.

We do compliance outreach, we hold seminar workshops that if you’re not interested and you think you don't qualify for an SCL you can attend one of our workshops to even, you know, you want to enhance your compliance program that you already have in place. We provide counseling. We can even help you build your internal control program. And we do the validated end user reviews.

Okay now this is the Export Management and Compliance Division Special Comprehensive License staff, Tom Andrukonis is our Director and we have - I have two other staff members, (Charlotte Holden) and (Tom Secily). If you need to reach us, as you can see you can reach us at 202-482-0062.

And I want to thank you very much. And if you have any questions we'll take those now. I'm giving it back to Linda.

Linda Abbruzzese: Thanks Regenita and thank you, Angela, for an excellent presentation. Now we'll go to our written questions from the Q&A. And I'm going to put our telephone on speaker.

Okay we'll start with the first question that I have from it looks like (Lydia McClure). The question is: "What is the process for requesting ECCN numbers currently not eligible for SCL? For example 2B350, can this be part of the commodities list on 752?"

(Lydia) we’re looking into that. You might want to clarify your question. I know you have a second part of that question which is, "Can the NDL be used to support manufacturing offshore if requested?" And you have a third question here, "When will the SNAP-R be eligible for the SCL?"

We’re working on this...

(Regenita Carol): They’re working on the SNAP-R right now.

Linda Abbruzzese: Okay we’re going to work on the SNAP part right now. So just one moment please. Okay we have some answers here for you, (Lydia). For the first question, "What is the process for requesting ECCN numbers currently not eligible for SCL? For example the 2B350, can this be part of the commodities list on 752?" Angela, what is the answer?

Angela Robinson: The 752 is strictly guided by the SCL and 2B350 is not - you cannot have an SCL. And no, it would not be part of the list. We would not put 7 - 2B350 on the commodities list on 752. So the answer is no.

Linda Abbruzzese: Okay thank you, thank you. Next question is, "Can the SCL be used to support manufacturing offshore if requested?" We’re looking into that one. And then the third question, "When will the SNAP-R be eligible for the SCL?" Do we have that ready? Not yet, okay no problem.

Angela Robinson: That’s in the process.

Linda Abbruzzese: That’s in the process. Okay it’s being implemented. And then the fourth question is, "BIS recently issued a new EMS audit module. Is there a SCL audit module available to SCL-holders and consignees?"

Angela Robinson: Yes.

Linda Abbruzzese: Yes? Okay. You know, what, (Lydia), if you'd like you can also verbally communicate your questions with us. We’re going to open the lines for audio for questions to be asked from your phone. So we'll get to you later on perhaps to help answer your question in a little bit more detail.

We'll go our next written question here from (Jeff Schroder). "Can you please restate the SCL benefits again?"

(Regenita Carol): (Unintelligible) in SCL. An SCL can be amended instead of having to maintain multiple licenses and issuing a new license you can amend the original license to add consignees, you can add items. Okay, you can also ship to multiple consignees and end users that if - the ones that are approved on your license.

You have the option to direct-ship between the license holder and end users or direct ship between the consignee and the end users. And this is only the ones that are approved on the SCL license. And the SCL is valid for a four-year period and you have the possibility of a renewal for another four years instead of the (validator) license is only for two years. Those are some of the benefits.

Linda Abbruzzese: Okay, thank you. Next question is from (Karen Wyman). "Can you please give us some examples of how an SCL has been used? What type of situations have warranted the SCL?"

(Regenita Carol): Well like I said before if you have - if you’re in the market and you have multiple shipments of items that’s going out you don't have to come in each time to apply for a license. It’s only for benefits of exports who have multiple shipments.

Linda Abbruzzese: Okay, thank you. Next question here is from (Colleen Dupree), I don't know how to pronounce the last name, excuse me. "Would the SCL impact change the need to get individual State Department licenses for USML parts?"

(Regenita Carol): Yeah, this is a separate license, separate regulation. You still have to, you know, go through the State Department if it’s a USML part.

Linda Abbruzzese: Okay, thank you. The next question here from (Kelly Anderson). "Can you comment on whether the DDTC has the same type of licensing ability for (ITAR) items, in other words, are there SCLs with DDTC?"

(Regenita Carol): Okay, with that question you have to contact the Department of States.

Linda Abbruzzese: Okay. Department of State, do we have that phone number or -

Angela Robinson: Two oh two, six six three, one two eight two.

Linda Abbruzzese: Can you repeat that again? 202...

Angela Robinson: ...663-1282.

Linda Abbruzzese: Thank you - thank you, Angela. Next question here from (Brett Harris), "Earlier in the presentation it was stated that spare parts are eligible for an SCL. Can the SCL be used to send items that are intended for use as spare parts even if the original equipment was not exported from the United States?"

Okay, Angela.

Angela Robinson: For the question for (Brett Harris), we'd need to ask - we want to ask you that call in so that we can get a little more details. But basically as long as the - if you send the us item in question, the equipment, wherever, if it was legally exported to that destination then that would then carry on to whether or not you can do the SCL for the spare parts.

So there’s some more things that we need to ask you in person to ask - to fully answer that question. So if you can actually give a call to the EMCD office then they'll be glad to assist you with that.

Linda Abbruzzese: Great, thank you Angela. Next question here from (John Blevins), "How can we expedite processing of export license application for multiple shipments of the same product to different customers/end users in the same country? Or is there a different license available other than individual licenses?"

(Regenita Carol): That - yeah, this is where you would want to apply for an SCL when you have multiple shipments to multiple end users this would be very beneficial for your scenario.

Linda Abbruzzese: Okay great. Thank you. I know we still have a couple more questions, we'll answer a couple more questions on the written part and then we'll go to the verbal open queue telephone questions.

Next question here is from (Cindy Roberts), "Can consignees in multiple countries be on one SCL or would they be separate SCLs required for each country?"

(Regenita Carol): Consignees can be in multiple countries on one SCL.

Linda Abbruzzese: Thank you. (Tammy Tagressi) asks what is the validity period of a SCL?

(Regenita Carol): The validity period for an SCL is four years with the possibility of an extension another four years.

Linda Abbruzzese: Okay great. Next - okay it looks like those are all the written questions we currently have. And I know that there’s a couple maybe piggy-back questions from (John Blevins) and it looks like (Karen Wyman) so please let’s open the lines for everyone and then they can ask their individual questions. Please press star 1 on your telephone.

Coordinator: Thank you. And if you do have a question please press star 1 and record your name clearly, again please pres star 1. (Karen Wyman), your line is now open.

(Karen Wyman): Thank you. I did want to go back to my question, can you give us some specific examples of how the SCL has been used? Certainly not naming a company but types of products and how they've used the SCL to their benefit?

(Regenita Carol): Well I - this is (Regenita). I see a lot of replacement parts and stockpiling, a lot of semiconductor parts. You know, if you have like multiple shipments going to a company, your consignee or the end user, this will be very beneficial.

(Karen Wyman): Now do you normally need advanced warning or advanced knowledge that you’re going to be doing this over the period of a year or two years or can you do it and hope that you’re going to be perhaps providing these products over an extended period of time?

(Regenita Carol): No, once you come in for a pre-consultation and like I said within that four year period you can just ship without having to come in to let the government know what you’re doing. Everything is approved up front.

(Karen Wyman): Okay. Thank you.

(Regenita Carol): Okay?

(Karen Wyman): Yep, thank you.

Coordinator: Our next question comes from (John Blevins), your line is now open.

(John Blevins): Good afternoon. Our question was around quantities for the SCL. Is there a specific limit to the quantity of material shipped or do we have to specify that quantity in advance when we’re applying for the license?

(Regenita Carol): You do have to specify as you have to give, you know, once you have your meeting you have to give us some idea of what type of business you’re going to be doing and the, you know, estimated limit of the quantities. Okay?

(John Blevins): And then that license is valid up to that quantity or we reapply or notify somebody if we’re going to ship over that quantity?

(Regenita Carol): Well that’s really not for the license portion, the license officer he can probably better tell you than I can. But to my understanding it’s not really a limit. You just have to let them know pretty much about everything that’s going to be going on.

Everything has to be in your narrative once you submit your application. And pretty much come quite to point, you know, what you’re going to be doing and pretty close to the quantity that you think it’s going to be.

(John Blevins): Okay, thank you.

(Regenita Carol): But you don't have to reapply. The only time you'd need to amend your license is if it’s a new item. But I see here you said 100 plus shipments. You don't have to really specify 100, 200, you just have to - they’re going to qualify by ECCN numbers, you know, countries, that sort of thing but not by quantity.

(John Blevins): Okay so it’s not limited by quantity?

(Regenita Carol): No.

(John Blevins): All right thank you.

Coordinator: Our next question comes from (John Wicker), your line is now open.

(John Wicker): Thank you. I have a question concerning extending an SCL. We have an SCL which is expiring the end of the year and we’re starting to put the paperwork together to apply for a new one. But if I can get this one extended I think everybody would be better off. What do I need to do to do that?

(Regenita Carol): You need to first contact your license officer. Do you know his name?

(John Wicker): I'm sorry, I don't.

(Regenita Carol): What is your name again?

(John Wicker): (Wicker), (John Wicker). It’s (Excelis).

(Regenita Carol): Oh (Excelis).

(John Wicker): S29.

(Regenita Carol): Okay so what you need to do - give me your telephone number.

(John Wicker): Nine seven eight, seven eight seven, four one six four.

(Regenita Carol): Okay Mr. - I'm sorry, 48-4164?

(John Wicker): Four one six four.

(Regenita Carol): Okay, Mr. (Wicker), I will give you a call later on today and let you know the process, okay?

(John Wicker): Thank you very much. I appreciate it.

(Regenita Carol): (Regenita Carol). Okay.

Coordinator: Our next question comes from (Brad Harris), your line is now open.

(Brad Harris): Okay, thank you. I understand that SCLs may be available for shipments to China. How would this square with the requirement for PRC end user statements? Do you have to get an end user statement in order to apply for an SCL? And if so how do you determine the quantity and value of what you’re going to ship if it’s sort of open ended?

(Regenita Carol): Well China is a little different so I would definitely have to talk to my director about that. So if you can give me a call on Monday and I'll, you know, I'll look into that.

(Brad Harris): Great, thank you.

(Regenita Carol): Okay.

Coordinator: (Debra Chang), your line is open.

(Debra Chang): I had a question concerning the description of replacement parts. Let’s say you had a product on your SCL which has, you know, let’s say 100 replacement parts. Do you need to itemize every single replacement part or you can say replacement parts for this specific product?

(Regenita Carol): If it’s different ECCN numbers you have to say that the - they go by the ECCN. That’s how they qualify.

(Debra Chang): Oh they would all have the same ECCN.

(Regenita Carol): But pretty much the license officer - you want to have all the product information and everything once you submit it?

(Debra Chang): Yeah.

(Regenita Carol): Okay.

((Crosstalk))

(Debra Chang): ...descriptions.

(Regenita Carol): Okay. Well, yeah, you just need to send all that in and just the ECCNs that it falls under.

(Debra Chang): Great, thank you.

Coordinator: Next question comes from Miss (Cerna), your line is open.

(Lucy Cerna): Hi, my name is (Lucy Cerna). I had a question, you mentioned about the VEU review, the validation end user review. Is that the same as the statement by ultimate consignee and purchaser that is provided on the form the BIS711?

(Regenita Carol): The VEU review...

Linda Abbruzzese: Yes.

(Regenita Carol): Now the validated end user review, that’s different. Yeah, that’s different.

(Lucy Cerna): It’s the same?

Angela Robinson: Different.

(Regenita Carol): I'm sorry?

(Lucy Cerna): So it’s the same?

Angela Robinson: Same, no.

(Regenita Carol): No that’s a different review.

(Lucy Cerna): Oh okay.

Coordinator: Our next question comes from (James Anzalone), your line is open.

(James Anzalone): Yes, good afternoon. My question is regarding the timeframe for the comprehensive license from initial review through the license granting. Could you give me some idea of what the normal turnaround time would be for something like that?

(Regenita Carol): Okay, as I mentioned the internal control program portion comes to my office, the EMCD and that normally takes between two to four weeks to review. Now the license portion is - that’s left up to the workload of the license officer so I can't really state how long it will, you know, take him to review that documentation because it depends on his workload and it depends on if he has any questions or, you know, if they may not be submitted. So I really can't say that for that portion.

(James Anzalone): Okay would it be safe to assume that it might be somewhere along the order of a standard license application review period which range anywhere from, you know, a week or two to six weeks?

(Regenita Carol): Yes we can safely say that.

(James Anzalone): Okay but the bottom line is here is the ICP review would also add about two to four weeks...

(Regenita Carol): Yes.

(James Anzalone): ...for all processes.

(Regenita Carol): Right, yeah. As long as, you know, you follow the ICP guidelines and include all the information that we recommend this should be - it shouldn't take that long.

(James Anzalone): Okay very good. Thank you.

Coordinator: Our next question comes from (John Blevins), your line is now open.

(John Blevins): Good afternoon again. We wanted to build upon the People’s Republic of China question earlier. Are there other countries that you know of that are problematic in trying to get an SCL for?

Angela Robinson: Sir?

(John Blevins): Yes.

Angela Robinson: What do you mean in terms of saying it’s problematic? What do you mean by that?

(John Blevins): Well are there other countries that it’s difficult to get an SCL approved to? You said that there were some special considerations with the People’s Republic of China earlier. Are there other countries similar to that that have special considerations that need to be taken into effect?

Angela Robinson: I don't remember her mentioning anything about special considerations for PRC.

(Regenita Carol): No the countries I said were not eligible were the Cuba, Iran, Iraq, North Korea, Sudan and Syria. And BIS may consider other countries as - on a case by case basis but that may be because there may be other issues with that.

Angela Robinson: You know, foreign policy changes...

(Regenita Carol): Right.

Angela Robinson: ...things of that nature. They may affect at that particular time whether or not a particular license maybe granted. But it’s nothing up front about PRC it’s just saying that, you know, things change and today - the way things change from day to day at that time there may be a foreign policy change that may affect whether or not an SCL can be approved to that particular destination. That’s simply what it means, nothing else. It’s not problematic for the PRC.

(John Blevins): Okay so I misunderstood your response to someone’s earlier question around the PRC.

Angela Robinson: Right, but that was more of a question for clarity for something that they want to do...

(Regenita Carol): Right.

Angela Robinson: ...it has nothing to do with it being problematic for the PRC. That’s a specific question pertaining to their industry.

(John Blevins): Okay.

Angela Robinson: All right.

Coordinator: If you have any further questions or comments again please press star 1 and record your name clearly, again please press star 1. I show no further questions.

Linda Abbruzzese: Okay great. Well thank you very much everybody for participating in today’s Webinar. Now for those of you who have questions maybe after this presentation please take a moment to note the contact information that (Regenita) had indicated earlier in this Webinar. It is on your screen, you can contact the Export Management and Compliance Division Special Comprehensive Licensing staff at 202-482-0062.

Remember for those of you also check out the Website, Bureau of Industry and Securities Website at www.bis.doc.gov. And also check out the Commercial Services Website which is www.export.gov for more information on upcoming Webinars such as this.

I'd like to thank our speakers and also if you have - (Regenita) will answer any other questions that you have submitted and will submit after this Webinar so she will be available and definitely there to help you with any of your additional questions.

I'd like to thank both of our speakers, Angela for her participation and also (Regenita) and also to all of our participants. And please check your email boxes for more information on upcoming Webinars. Good bye.

Coordinator: That concludes today’s conference. Thank you for participating, you may disconnect at this time.

END