EXPORT BASICS
U.S. export law can be confusing, in part because it is administered by several different U.S. government entities. Three key entities are:
- Bureau of Industry and Security (BIS) (U.S. Department of Commerce)
BIS administers the Export Administration Regulations (EAR) that applies to all U.S.-origin "commercial" and "dual-use" items, and related technical information. "Commercial" and "dual-use" items are those that are not specifically designed for military use. - Directorate of Defense Trade Controls (DDTC) (U.S. Department of State)
DDTC administers International Traffic in Arms Regulations (ITAR) that applies to all U.S.-origin items specifically designed for military use, and related technical information. - Office of Foreign Assets Control (OFAC) (U.S. Department of the Treasury)
OFAC administers U.S. imposed embargoes and other country specific sanctions, as well as sanctions against individuals and other entities, such as the Specially Designated Nationals (SDN) list that identifies suspected terrorists.
Ariba's compliance with U.S. export law focuses in three areas:
- Export (including "deemed export"*) of Ariba products by Ariba, our customers and resellers
- Use of Ariba products, when such use could involve the export of any Ariba Product, other U.S. origin items, or export-controlled technical information
- Handling of our customers' and other third party export-controlled technical information
* A "deemed export" is defined by Export Administration Regulations as export (or disclosure in the case of export controlled technical information) to a "foreign national". A "foreign national" is an individual who is not a:
- U.S. citizen
- U.S. permanent resident alien ("green card" holder) or
- lawfully admitted refugee or asylee
More information on compliance in these three Ariba-specific areas can be found at Exporting and using Ariba products and Handling Export-Controlled Technical Information
General information on U.S. export law can be found at the web sites listed above for BIS, DDTC and OFAC.
