ACIP Submits Comments on Deemed Exports

Deemed Exports Other

​The Export Control Practitioners Group (ECPG) sent a letter signed by fifteen trade associations, including ACIP, to the National Security Advisor, General James Jones and the National Economic Council Director, Mr. Lawrence Summers, advising the administration to focus on simple, transparent and efficient reform of the export control system. ACIP supports the ECPG recommendations that were sent along with the letter that specifically relate to deemed exports, as the current controls are, “often unilateral in the way they are executed and impose a significant and often unnecessary burden on the global operations of U.S. companies. Controls on deemed exports and intracompany transfers must be updated to reflect a post-Cold War environment, where auditable company internal control programs are an established part of globalized U.S. business.” ACIP also supports ECPG’s recommendation to limit deemed export licensing requirements to sensitive multilaterally controlled technology.​