Considerations for Export Control Compliance
Expanding on my previous blog post regarding export control and how it is defined, there are several other factors to take into consideration to help ensure compliance.
- Record Keeping
- All export records must be kept for five years after license expiration, even if no license required (NLR).
- Maintain a log of all exports (e.g. method of transport, supplement technical data)
- Keep a copy of the invoice, bill, and data exported if physically exported
- Keep a record of servers, usernames, and data sent when using any electronic medium
- Hiring Foreign Nationals and Outsourcing
- Where will work be done?
- Where is the end-use?
- Access by a FN on-site to a database or file share with technical data is still an export
- Use ACLs and/or Domains to grant appropriate permissions to employees of U.S. citizen ship and foreign nationals.
- Consider physical badge colors and combinations to identify U.S. citizens, contractors, and foreign nationals.
- Other considerations:
- Protect intranet web pages
- Exchange calendar settings and items
- Email chains
- Print outs, desk tops
- Teleconference lurkers