Certified U.S. Export Compliance Officer (CUSECO) Exam

This domain provides foundational knowledge of the regulatory framework for U.S. export control laws and compliance.

Export Control Laws and Regulations
- Understanding the Export Administration Regulations (EAR)
- Overview of the International Traffic in Arms Regulations (ITAR)
- U.S. sanctions and embargoes (Office of Foreign Assets Control - OFAC)
- Overview of U.S. Customs and Border Protection (CBP) and the role in export compliance
Key Regulatory Agencies
- U.S. Department of Commerce – Bureau of Industry and Security (BIS)
- U.S. Department of State – Directorate of Defense Trade Controls (DDTC)
- U.S. Treasury Department – Office of Foreign Assets Control (OFAC)
- U.S. Census Bureau and the Automated Export System (AES)
- Federal Bureau of Investigation (FBI) and other enforcement agencies
Export Compliance Programs
- Purpose of export compliance programs
- Components of an effective export compliance program
- Responsibilities of a U.S. Export Compliance Officer (CUSECO)

This section focuses on understanding the procedures and requirements for obtaining export licenses and managing controlled goods and services.

Export Control Classification Number (ECCN)
- Determining whether an item is subject to the EAR
- Export Control Classification Numbers and how they apply to items
- Export licensing requirements based on ECCN classification
ITAR and U.S. Munitions List (USML)
- Classification of defense articles under ITAR
- Export licensing under ITAR
- Differences between EAR and ITAR controls
Licensing Procedures
- Types of export licenses (individual, general, and license exceptions)
- License application process and timelines
- Denial and approval of export licenses
- Record-keeping and compliance with export licensing conditions
Export Restrictions and Prohibited Exports
- Countries and entities subject to sanctions or embargoes
- End-user and end-use restrictions
- Prohibited exports to certain foreign governments and entities
- Special compliance considerations for military, dual-use, and sensitive technologies

This domain evaluates the knowledge of U.S. sanctions and embargoes, including restrictions on certain countries, individuals, and entities.

Sanctions Programs and Enforcement
- Overview of U.S. economic and trade sanctions programs (OFAC)
- Types of sanctions (comprehensive, targeted, etc.)
- Specially Designated Nationals (SDN) and Entity List
- Blocked persons and entities
Country-Specific Sanctions
- Detailed review of sanctions programs for specific countries (Cuba, Iran, North Korea, etc.)
- Understanding secondary sanctions and extraterritoriality
- Compliance with country-specific export restrictions
Exporting to Restricted or Prohibited Entities
- The U.S. Entity List and how it impacts exports
- Understanding Denied Party Screening (DPS)
- Due diligence on customers, partners, and end-users

This section emphasizes the importance of maintaining accurate records and documents to ensure compliance with U.S. export laws.

Documentation Requirements
- Essential export documentation (commercial invoices, export declarations, etc.)
- Export Compliance Statements and certifications
- Recordkeeping requirements under EAR and ITAR
- Export license applications and approval notices
Automated Export System (AES)
- Reporting requirements for exports via the AES
- Filing Electronic Export Information (EEI)
- AES compliance and validation procedures
Retention and Auditing of Export Records
- Retention periods for export records (5 years for EAR, 6 years for ITAR)
- Responsibilities of the export compliance officer in maintaining records
- Auditing procedures and internal controls for export transactions

This domain covers strategies for identifying, assessing, and mitigating export compliance risks within an organization.

Risk Assessment Process
- Identifying export compliance risks in an organization
- Evaluating the risks of doing business with certain countries, entities, and individuals
- Assessing the export control status of products and services
Risk Mitigation Strategies
- Screening procedures for customers, third parties, and vendors (SDN list, Entity List, etc.)
- Risk-based decision-making process
- Creating export compliance policies and procedures
- Training programs for staff to reduce risks
Internal Auditing and Monitoring
- Export compliance audits and inspections
- Continuous monitoring of export transactions
- Corrective actions for compliance deficiencies

This section focuses on creating an effective export compliance training program to educate staff and stakeholders.

Training Program Development
- Developing and implementing an export compliance training program
- Ensuring all employees are aware of export controls and regulations
- Conducting regular training and updates to account for changes in regulations
Training for Key Personnel
- Specialized training for compliance officers, export control managers, and legal teams
- Customizing training for different business units (sales, procurement, engineering, etc.)
Monitoring and Enforcement of Compliance
- Evaluating the effectiveness of training programs
- Encouraging self-compliance and reporting of violations
- Procedures for handling non-compliance by employees

This section deals with how to monitor and enforce export compliance programs effectively within the organization.

Auditing Export Transactions
- Conducting internal audits to review export documentation and processes
- Identifying potential non-compliance issues
- Creating a corrective action plan based on audit findings
Handling Violations
- Identifying violations of export laws and regulations
- Procedures for reporting violations to appropriate authorities
- Managing voluntary disclosures and the enforcement process
Penalties and Enforcement Actions
- Potential penalties for non-compliance (civil and criminal penalties)
- OFAC, BIS, and DDTC enforcement actions
- Impact of violations on business reputation and operations

This domain covers the latest developments in global export compliance and how they affect U.S. businesses.

Global Export Control Trends
- International collaboration on export controls (Wassenaar Arrangement, etc.)
- Changes in global trade policies and their impact on U.S. exports
- Export compliance in the context of emerging technologies (e.g., AI, blockchain, cybersecurity)
The Role of Customs and International Trade Agreements
- Understanding the role of international trade agreements (WTO, free trade agreements, etc.)
- Compliance with export procedures under different international frameworks
- Customs regulations and trade facilitation
Impact of Global Compliance Standards
- Global sanctions regimes and how they relate to U.S. export controls
- Adapting to different national export control systems
- Ensuring multi-jurisdictional compliance in global trade operations

This section covers the ethical and professional responsibilities of a U.S. Export Compliance Officer.

Ethical Decision-Making
- Ethical dilemmas in export compliance
- Balancing business goals with compliance requirements
- Acting in the best interest of the organization while ensuring legal compliance
Professional Integrity
- Maintaining transparency and honesty in reporting export activities
- Confidentiality of sensitive export-related information
- Addressing conflicts of interest and ensuring unbiased decision-making

2.2 MB

413 pages