Work Product Slide Examples

JOHN P. PRIECKO JOHN P. PRIECKO Work Product Work Product –– PowerPoint ExamplesPowerPoint ExamplesA More AttentionA More Attention--Getting, Meaningful and Visual Approach Getting, Meaningful and Visual Approach

There is a much better way….

A B E T T

E R W A Y . . .

Trade Compliance Solutions

A More AttentionA More Attention--Getting, Meaningful and Visual Approach Getting, Meaningful and Visual Approach to Better Communicate the Trade Compliance Messageto Better Communicate the Trade Compliance Message

Something far different than “death by PowerPoint.”

KEY TRADE CONTROL PLAYERSKEY TRADE CONTROL PLAYERS

Departments of:

� Commerce (DOC)� Bureau of Industry & Security (BIS)

� Defense (DOD)� Defense Technology

Security Administration (DTSA)

� State (DOS)� Directorate of Defense Trade

Trade Compliance Solutions

A B E T T

E R W A Y . . .

All with “Very Different”

World views.

� Homeland Security (DHS)� Customs & Border Protection (CBP)

� Justice (DOJ)� Federal Bureau of Investigation (FBI)� Bureau of Alcohol, Tobacco, Firearms

and explosives (BATFE)

� Treasury (DOT)� Office of Foreign Assets Control (OFAC)

� Directorate of Defense Trade Controls (DDTC)

CASE REVIEW PROCESSCASE REVIEW PROCESS

DOSDirectorate of Defense Trade Controls

(DDTC) [Munitions]

DOCBureau of Industry & Security (BIS)

[Commercial & Dual-Use]

APPLICANT

OTHERGOVERNMENT

Administered under the International

Administered under

DOD

Defense Technology Security Administration

(DTSA)

DEFENSE AGENCIESJOINT STAFF &

MILITARY SERVICES

GOVERNMENTAGENCIES

Administered under the International Traffic in Arms Regulations (ITAR)

Administered under the Export AdministrationRegulations (EAR)

Trade Compliance Solutions

PROCESS REALITYPROCESS REALITYIt’s not Nuclear Physics, but ...

AMCO

DOSDDTCPDA

SAFIAD

PMRSAT

DOE

DOTNSA

HQAMC

OFAC

BATF

SD

USASAC

PM

PMPM

NDPC

NASA

ACDA HQ

SVCS

DOS

NASA

JCS

Business Units

NV

NRL

CO

TSO

DIA

CIA

DASADE&C

NIPO01/3

FR

UK

Labs

LabsTD

ISPJCSJ-5

DSCA NAV AIR

POA&T

DARPA

SPAWAR

- WARNING -Actual Cases May

Be Better or Worse!

TRISVC

EXCOM

J-3 CINCS

PEOS PM

PM

PM

USMCOPNAV

N87

N88

N60

AQ

DTSALD

REDTEAM

MTEC

TECHS PO

Trade Compliance Solutions

Applicant

Defense TechnologySecurity Administration(DTSA) staffs to otherDefense Department

organizations

Reply to DTSA(within 25 days)

14 Day Extension

DOS

DOC

THE PROCESSTHE PROCESS

Jurisdictional DeterminationsEscalation

organizations14 Day Extension(DTSA approval)

A Decision byDTSA within

2 working days

Potential Escalation by DOD reviewers

within 3 working days

Escalate?

YES

NO

DOC(Others as appropriate)

Trade Compliance Solutions

SITUATION: You are a US manufacturer of a wide-range of commercial off-the-shelf and dual-use connectors for a variety of uses.

You are approached

JURISDICTIONAL DETERMINATIONS JURISDICTIONAL DETERMINATIONS Practical ApplicationPractical Application

You are approached by a military buyer who wants one of your products with only one minor change.

Trade Compliance Solutions

A B E T T E R W A Y . . .

2. Which connector is

1. How does that change impact jurisdiction?

JURISDICTIONAL DETERMINATIONS JURISDICTIONAL DETERMINATIONS Practical ApplicationPractical Application

2. Which connector is under DOS jurisdiction and why?

3. Are the two different connectors the same in form, fit and function?

EAR99 ?

Trade Compliance Solutions

A B E T T E R W A Y . . .

SITUATION: You are a US manufacturer of common butterfly valves used for a wide range of industrial applications including marine, water, oil, gas industries, food, dairy, brewing, pharmaceutical, beverage and chemical/process industries.

JURISDICTIONAL DETERMINATIONS JURISDICTIONAL DETERMINATIONS Practical ApplicationPractical Application

beverage and chemical/process industries.

You are approached by a military buyer who wants one of your products with only a few minor changes for safety considerations.

Trade Compliance Solutions

A B E T T E R W A Y . . .

The buyer does not want to make any modifications whatsoever to the Pressure Rating and Temperature Range. However, the customer decides to only make small changes to the upper shaft stem.

1. What are the differences

JURISDICTIONAL DETERMINATIONS JURISDICTIONAL DETERMINATIONS Practical ApplicationPractical Application

EAR99?

EAR99?

1. What are the differences between the two items?

2. Which one is under DOS jurisdiction?

3. Are the two different items the same in form, fit and function?

Trade Compliance Solutions

A B E T T E R W A Y . . .

SITUATION: An exporter had several different cases

pending with the Treasury Department, OFAC, that

constituted a total of 50 separate administrative violations.

Maximum Administrative Fines

On January 1st:

Trade Compliance Trade Compliance -- ConsequencesConsequencesNew Math New Math -- More Compelling Reasons to ComplyMore Compelling Reasons to Comply

On January 1st:

2006 - 50 x $11,000 = $550,000

2007 - 50 x $50,000 = $2,500,000 4½ times greater than 2006

2008 - 50 x $250,000 = $12,500,000 5 times greater than 2007 and almost 23 times more than 2006

-- Dramatic Changes with Growing “Significant” Impact Dramatic Changes with Growing “Significant” Impact --

Trade Compliance Solutions

A B E T T E R W A Y . . .

In addition to a long list of USG mandated Remedial Compliance Measures there are many other detrimental, potentially devastating consequences including:

� Compliance Monitor� Denial of export privileges� Debarment from USG contracts � Federal prosecution

Trade Compliance Trade Compliance -- ConsequencesConsequencesWhat’s the cost of making mistakes?

� Federal prosecution� Damaged credibility� Adverse publicity � Significant legal fees� Huge fines and lawsuits� Imprisonment� Criminal record� Loss of: award fees, future business, other

contracts, share-value and share-holder confidence…

Trade Compliance Solutions

A B E T T E R W A Y . . .

1. Commitment Globally, Horizontally and Vertically

2. Written & Followed Standardized Policies, Processes and Procedures

3. Initial & Recurring Education & Training

4. Effective Organization & Staffing

5. Timely & Accurate Jurisdiction & Classification

6. Cradle to Grave License Management

Trade Compliance Trade Compliance -- Core Best PracticesCore Best PracticesTop Ten EssentialsTop Ten Essentials

6. Cradle to Grave License Management

7. Thorough Due Diligence

8. Complete Documentation / Recordkeeping

9. Periodic External & Internal Assessments / Audits

10. Dealing with Violations / Non-Compliance

What happens when a trade compliance What happens when a trade compliance program is missing an essential element?program is missing an essential element?

Trade Compliance Solutions

A B E T T E R W A Y . . .

Trade Compliance Trade Compliance -- Core Best PracticesCore Best PracticesTop Ten EssentialsTop Ten Essentials

Objective

DisciplinedAccurate

Prevention

Complete

Periodic External & Internal

Assessments/Audits

Dealingwith

Violations / Non-Compliance

Independent

Proactive

Commitment Globally, Horizontally and Vertically

Disciplined

Multi-Media

Quality

SOLID FOUNDATIONSOLID FOUNDATION

Varied

ChecklistsConsistent

Communication

CurrentValidated

Automated

SecurityLayered

Active

Accurate

Written & Followed Standardized Policies, Procedures and Processes

Initial & Recurring Education & Training

Effective Organization & Staffing

Timely & Accurate Jurisdiction & Classification

Cradle to Grave License Management

Thorough Due Diligence

Documentation / Recordkeeping

Integrated

Involved

Trade Compliance Solutions

Trade Compliance Solutions

13

Reality:“It’s not that hard to do! With a little extra effort your

presentations can be much more visually & verbally interesting,

stimulating and increase learning & retention a great deal as well.“

JOHN P. PRIECKO JOHN P. PRIECKO Work Product Work Product –– PowerPoint ExamplesPowerPoint ExamplesA More AttentionA More Attention--Getting, Meaningful and Visual Approach Getting, Meaningful and Visual Approach

Trade Compliance Solutions

A B E T T

E R W A Y . . .

JOHN P. PRIECKO President and Managing Partner

Trade Compliance Solutions

9312 Manassas Drive, Manassas Park VA 20111-8203

Phone: (703) 368-0384

Cell (703) 8956-1110

Email: jpriecko@comcast.net

A More AttentionA More Attention--Getting, Meaningful and Visual Approach Getting, Meaningful and Visual Approach to Better Communicate the Trade Compliance Messageto Better Communicate the Trade Compliance Message