CPI Investigations Flashcards
(19 cards)
How long can you detain something pending further investigation to get a license determination?
As long as necessary.
The Electronic Export Information (EEI) must be filled within how many hours prior to an export?
24 hours
When is Electronic Export Information (EEI) normally required?
When the shipment is over $2,500.
What do you put in a PSA ROI?
Location, what you told them, who was there (present)
What do you use to deconflict all leads?
The Export Enforcement Coordination Center (E2C2)
Who is the POC for all licensing jurisdiction request?
Exodus Command Center (ECC)
Whats the denied persons list?
A Bureau of Industry and Security (BIS) list of individuals and entities barred from exporting goods and services from the U.S. based on prior EAA/EAR/IEEPA violations.
What are the elements 22 USC 2278 Control of Arms Exports and Imports?
- Willfully
- Exports
- An Article listed on the Munitions List or a technology relating in a significant fashion to an article on the Munitions List
- Without a license
What are the presidential authorities per IEEPA?
- Investigate, regulate, or prohibit any transactions in foreign exchange
- Investigate, regulate, or prohibit financial transfers involving a foreign country or foreign national
- Investigate, regulate, or prohibit the importing or exporting of currency or secuities
What are the elements of a violation of IEEPA regulations?
- Knowing and willful
- Covered transfer, export, import, travel transaction, or contract performance
- Without U.S authorization
What is 18 USC 554 (outbound smuggling section)?
This statute criminalizes the fraudulent or knowingly exporting or sending from, or attempting to do either, any merchandise, article or object contrary to ANY law or regulation of the U.S.
What is USML?
Its a list showing what items require a license for exporting and brokering activities. (single use items, for military only.
What is CCL?
Commerce Control list for most commercial and dual use items that require a export license under the Export Administration Act of 1979 (EAA)
What is CPI most important priority?
Interdiction.
Stop the illegal export from reaching its destination due to national security implications. Interdiction of export over arrest-prosecution s secondary.
How do you obtain license determination?
Agents must submit request to the ECC through the Exodus Accountability and Referral System (EARS)
What are the three types of CPI investigations?
Proactive
Reactive
Historical
what is transshipment?
For purpose of giving an illegal export the appearance of legitimacy, shipping a commodity from the U.S.
How do you prove specific intent?
- Undercover engagement (e-mail, telephonic, in-person meets)
- Documents obtained through search warrants
- Historical documents (legal export caveats on docs)
- Interviews (admissions of guilt
- RFQs
- Written communications
Whats “Deemed Exports” (intangible transfer)?
An export of technology or source code (expect encryption source code) is “deemed” to take place when it is released to a foreign national within the United States.
