U.S. Department of Commerce

Bureau of Industry and Security

Update 2015 Conference -- Washington, D.C.

Remarks of Kevin J. Wolf

Assistant Secretary of Commerce for Export Administration

November 2, 2015

 

KW2015

 

Before I begin, I want to get a group photo. Last year I had a lens, this year a brought a fish eye so I can get all of you in. Sorry, so say cheese everybody, say cheese. Karen mentioned the game last night which I stayed up way too late watching. I grew up in Missouri as a Cardinals fan so congratulations to the Royals on their first legitimate World Series win. A lot of people here remember 1985, okay that’s good! So, thank you Eric. It is still an honor to serve with you, you are a terrific leader, public servant and good friend, and better yet, you are making a difference. Thanks to the attendees, export controls don’t exist just to make half of your lives more difficult and the other half of your lives full of billable hours. They exist for serious national security and foreign policy reasons and unless people understand them then they can’t be complied with. Unless people commit the resources and the time to complying with them, then the objectives aren’t met, so you’re all here for the greater good, thank you. Some of you have asked in the hallways, how my current job now, going on 6 years compares to my previous life. It is true that the longer I’m here, the shorter my patience gets, but I am still committed every day to the purpose of the objectives that I just described and to make the system as least burdensome as possible. We are not there by any means, but its’ far better than it was when David, Eric and I arrived. And as Eric described, we’ve set up a structure that allows I believe over time, for constant refinement and improvement which is a key element to the new system. In any event where I get frustrated, I think about the reasons I started and that keeps me going. And also my office is only three stories up, so I’d only break a few legs if I were to jump. Anyway, I will brag about my terrific staff, my deputy and office directors in a little bit, but since this is an update conference let me get straight to some updates on some key things that Eric and Dan didn’t touch on.

So on the definitions rule, we are nearly done with very good quality internal drafts of the rules. Thank you also for the public comments that you sent in, particularly the ones that didn’t contain any profanity. This rule, the objective of this rule is to continue the process of harmonizing the EAR and the ITAR and to reduce regulatory burdens that exist merely by the differences between the two sets of regs. And as described, to the extent that there needs to be a reason for the difference between the two sets of regs, that is explained and laid out more clearly. The rule also take into account mod cons such as the internet, and Cloud storage. Because it’s not yet in final, the lawyers won’t allow me to tell you exactly what we are going to do, what comments we’ve accepted or rejected, but trust me I think most commenters, the thoughtful ones, will be relatively pleased with what we are going to come out with. We don’t have a due date yet, it will probably be at best at the end of the year, more likely just after the first of the year given the need for usual interagency clearance, but the substance of it is essentially done. We are nearly finished with a second proposed rule, on USML Category XII pertaining to night vision item sensors, lasers and gyros and things like that and then the corresponding Commerce equivalent. When we published the proposed rule we asked for candid and frank comments and we got them. So actually that was part of the plan, so that’s not a failure that’s actually a success. They’ve actually helped us, and this was also always part of the plan to make what would be a much better second proposed rule. Again I don’t have an exact date of when it will come out as a second proposed rule, but it will be soon. Sometime in the neighborhood of the definitions for those two are the first two rules in our queue. As Eric also mentioned, we are about ready to publish a proposed rule to update our slightly more than two-year-old aircraft and engines rules, both on the Commerce side and on the State side. And this is part of the effort with industry participation to make sure that the rules control exactly that which warrants control in the clearest way possible and are going to be regularly updated and refined. Because technology, and threats, and industry understanding, and industry misunderstanding evolved and the regulations need to evolve alongside of that as well. And it is appropriate that aircraft and engines are the first category since they are by far the biggest customers we deal with. As Eric I think mentioned, we have out now a notice of inquiry asking for comments on the next group of rules that we published involving vehicles and ships and materials and military and intelligence encryption and submersibles and the materials which includes armor. The due date is December 8th, so if you are in any of those effected industries, please send us in your thoughts, and then what we do is we take your ideas and then the ones that we’ve developed internally, and that will then translate into a proposed rule revising USML Category VI, VII, XIII, and XX and then the corresponding Commerce book ends. We received relatively few comments on the toxins and biologics rules that we published amending Category XIV, and, this is unrelated but in the same rule, the directed energy weapons rule. Again I don’t have a due date on that one but it will be after the topics that I just mentioned. This was a very difficult rule intellectually to work through. Not only the nature of the items, but it also involved a lot of parts of the U.S. government that have expertise and equity on the topic but aren’t normally involved in the export control system. And again, Eric mentioned that we know the transition from the USML to the CCL is painful for some. And in the short term it takes a lot of work and commitment, but I just wanted to also point out that all of this retraining and effort has really done a terrific job of ferreting out a lot of bad habits, even under rules that didn’t change that had crept into the system over the years. And whatever complaints, whatever difficulties, whatever hardships that you have in going through these, think about, as part of the transition effort, think about all of the burdens that no longer exist with respect to the items and related technologies and software that have transitioned over – no more brokering issues, no more defense services, no more registration, no more registration fees, no more fees for submitting a license application, that de minimis rule that’s really quite significant that Eric mentioned for non-embargoed countries, a much less burdensome direct product rule in the EAR than exists in the ITAR and as a condition of agreements, one page licensing forms for technology rather than complex MLA’s and TAA’s, no more need for permission just for the act of marketing or production overseas or calculation or reporting thereafter, simpler congressional notification requirements, no more having to deal with complex in furtherance of concepts, no purchase order requirements, which really allows for better business planning and thinking over time, over a 4-year period, about what a simple, a much more simple licensing system can be for you. And then of course all of the various license exceptions that Eric mentioned: STA, GOV for government shipments and RPL. And yes I know I’m going to talk a lot about, over the next couple of days, the complaints that you all have or your foreign companies have with respect to STA but it still puzzles me why folks would complain about signing a certification with respect to exactly the same information that would be required for the foreign party to give the U.S. party for the submission of an application anyway. Again we will talk about it, but that one still puzzles me. This is probably one of the situations where although we are responsive and friendly, I’m just going to say "Yeah, tough, suck it up."

Anyway, although the U.S. government’s implementation of the Wassenaar cyber intrusion rule isn’t really part of the reform effort, it is none the less a rule that has by far gotten the most attention out of any of our rules. So let me just give you an update and a status on that one. So the background of the rule is, normally we publish a couple months after agreeing in the regimes to whatever the controls were in the previous year generally, and the cyber intrusion rule which we are going to describe in more detail the next couple of day was agreed to in December of 2013, but unlike all other Wassenaar rules, as we begin to look into it more, we were uncertain that it would really have the very small scope and the small impact that was originally promised in terms of the objective of the rule. So in order not to be wrong, in order to not unnecessarily or inadvertently impose significant harm on the very critical cyber defense research industry and ecosystem, we decided to pull that rule out of our implementation of that year’s Wassenaar, and ask for comment. And just like with Category XII, we asked for candid and frank comments and boy did we get them. So the status is that we are still reviewing all of those comments. And when I say we, I mean not just regular export control agencies, but all the other parts of the U.S. government that have expertise and equity in the topic, cyber defensive research in particular. The only thing I can commit to you about the rule is that we won’t be going to a final rule on that topic as the next step. What the next step is, I don’t know yet because we are still working through the comments, we still have some other industry participation events to deal with and, again as I said, we still want to make sure that we get the input and expertise of all of the parts of the U.S. government, and we won’t proceed unless those in that ecosystem are comfortable with what we are doing.

So let me talk about some of the less discussed aspects of what we’ve been doing the last couple of years. We always speak a lot about the USML Category revisions, that’s great, it’s the core part of the reform effort, it’s a very easy metric to show progress, the number of categories. But there is a lot of really less sexy stuff that goes on to make the regulations better and less burdensome in order to accomplish the objectives of the regulations. We’ve done some pretty good revisions and updates in liberalizations of pretty much all of the license exceptions: TMP, RPL, GOV, and TSU. We’ve adjusted the validity periods for a license, and a practice within our licensing offices to make licenses a lot more tailorable and flexible given the fact that transactions are just not simply shipments of an item in a box from party A, to party B, to party C. We revised our support document requirements, which were heretofore one of the most convoluted part of the EAR. Specifically, we removed the requirement to obtain an International Import Certificate or Delivery Verification as well as the requirement to obtain a Statement of Ultimate Consignee, except for 600 series Major Defense Equipment, which is a very very small fraction of our total volume. So compare this to what existed when we started. Under the ITAR, the DSP-83 is the equivalent of that and it wasn’t required even when these items were on the ITAR, for the items that became Commerce controlled, because it only applied to significant military equipment. So oddly enough, you had a situation where the ITAR was less burdensome than the EAR in this legacy area. So we have dramatically reduced that burden that goes along with the process and the progress of license applications. And we estimate that for exporters on average it reduces 2,000 hours a year of regulatory burden. And on the back end of the licensing process, we substantially revised our license conditions practice and this has been manifested in what some of you have heard us refer to as the boilerplate that is at the beginning of each of our licenses. It had radically reduced the total amount of words and the total number of conditions that were routinely going into licenses, particularly those that did nothing more than restate obligations or prohibitions that were already in the regulations. And this has allowed for much more clear, much more consistent conditions, and again a lot fewer of them to reduce confusion. If, however, you, particularly for 600 series and satellite items, are receiving licensing conditions that are more burdensome than used to be the case when the items were ITAR controlled and all other things are equal, complain, don’t just stew about it. I mean, there are a lot of new people in the system both at the Defense and State and at the Commerce Departments, and we may not have had a particular history with your company or your past practices, and you know Mike Vaccaro is the head of the Defense Control Division, you should feel free to call him, anytime, day or night, his home number is 70..

So we also eliminated the Special Comprehensive License. This was a license structure that was very complicated, had a lot of conditions, and a lot of limitations, and a lot of words in the regulations and can all now be done far more simply under the practices that we’ve adopted for just regular ordinary licenses with a lot fewer words, a lot less paper, with literally an unlimited number of end users or other parties to the transaction all being within the scope of the same authorization. So we simply removed that and another thing that we are thinking about, that we are working on, is to expand the concept of the VEU program to effectively operate as a program authorization in those circumstances where you have multiple shippers, multiple exporters to one or a small number of recipients. We don’t have anything yet in writing on this, it’s an idea that we are working on with a few test bunny applications and probably at next year’s Update we will have some actual examples but I think that this is going to be a very clever way of reducing overall burden for the situations that are routinely approved with multiple exporters and the small number of recipients.

We are still working through the comments you all sent in on the harmonized Destination Control Statement idea that State and Commerce published., We realize that the current requirements have created a lot of confusion and unnecessary burden because they had the same objective with the groups of words, but the ITAR and the EAR were different for the same purpose. And as Eric mentioned, now that we have a common internal IT system, we are renewing the work that we started a few years ago to create a single export license form, one that would be common between BIS and DDTC, that one would apply to through a single internet based portal. It’s an IT project: a lot more work is needed on that and we are really going to need the help of industry on that to make sure it works and it is consistent with your current practices. I will give you, I’m going to wait until next year’s Update to go through a list of all the things that we also have on our list that we might not be able to get done.

I will be going into more detail on these rules at other sessions and others of our staff will in the next couple of days. But one of the purposes of a keynote speech, one of them, is to lay out sort of the big theme in a big idea. So I am going to lay out one now, which I think is really going to be in the end a terrific idea. And that is the creation of a common set of regulations between the ITAR and the EAR and basically rewrite, from the ground up, the ITAR and the EAR so that the words are common. This is not something that can be done, completed during the Obama administration. But it is something on which we can do a substantial amount of work and have it so that we can hand it off to whoever is in charge under the next administration. But take a step back and think, what is the purpose of export controls? Export controls are a semipermeable regulatory net that control the export, reexport and transfer of physical items, "thingies" as I call them, commodities in the legal term, software services and technology to certain end users, end uses and destinations for various foreign policy and national security reasons, and the EAR and the ITAR do exactly that. However, they have evolved over the decades in completely different structures. They have different terms, different phrases, different ways of prescribing their prohibitions, license application requirements, appeals procedures, record keeping requirements, penalty and disclosure policies, license exceptions and exemptions. The forms are different and although we are working on, as I just described, trying to harmonize them in the terms, the structures are all completely different, and so this is, I’m not just saying that the controls between the ITAR and the EAR need to be exactly the same, that’s not my point. It’s just that they are both a language that achieves the same objectives, except that one is Latin and one is Greek. And for most of their Cold War regulatory lives, this difference didn’t really matter. Those who were in the military world were funded in one way, and were one group of companies and people with one type of business, and those that were in the commercial and dual-use world were a different group. But with the end of the Cold War, and the evolving nature of COTS technologies and items for military applications, and intermingling of technology, and in fact in many areas where commercial development leads, the difference between the two sets of regs as such, creates an unnecessary regulatory burden. And so in order to ensure compliance with applicable U.S. laws, both U.S. and non-U.S. companies have to get used to and understand two very differently structured sets of regulations. And also as a result of decades of individual decisions that at the time made sense vertically, there has been created all sorts of cul-de-sacs, and variations between the two sets of regs that has not really made for an internally horizontally coherent structure of U.S. export controls. So this is really describing what the ultimate objective for phase III of the reform effort is: the creation of a single agency with a single set of regulations. It’s also part of the phase II effort which is to harmonize where possible the regulations. But it is also consistent by the way with an Executive Order that after the reform effort began, the President issued: Executive Order 13563 improving regulation and regulatory review, and he said he wrote, "A regulatory system must protect public health, welfare, safety and our environment while promoting economic growth, innovation, competitiveness and job creation. It must be based on the best available science and must allow for public participation and an open exchange of ideas. It must promote predictability and reduce uncertainty." And then it goes on to describe how to have regulations be the least burdensome possible. So the point of the grand idea of a common set of regulations is that there is no legal or policy reason to wait until phase III. There is no reason to wait to create a common set of regulations, the current statutory authorities for our regulations, IEEPA and the Arms Export Control Act, are sufficiently flexible for substantial revision to both sets of regs. So from the ground up, they wouldn’t be common. There would still be Title 22 and there would still be Title 15 but they would use the same words, the same structures, the same approach. Now of course they would identify the groups of items and the licensing policies for things that were subject to the Arms Export Control Act and those that there not but otherwise they would be a common set of words and one could look to either 22 or 15 and be able to know what the words are. It would be a radical reduction or an opportunity to radically reduce the total number of words in the export control regulations. It would take advantage of the last several years of thinking on a policy matter that we’ve been describing as part of the reform effort, and it would of course then ultimately enhance the objectives of the controls – of understanding, compliance, and enforcement. And if the phase III ever comes to be, then it would be all the work that would need to have been done anyway to create a single set of regulations, and if phase III never comes to be, if no law comes into being that would allow that, then we have achieved exactly the same benefits and opportunities and the purposes of phase III by creating two common sets of regulations between CFR 22 and CFR 30. So you know, this would need to be again a 0 based effort. If somebody can’t describe a reason why an existing control, it gets tossed. Saying that’s the way we’ve always done it would be an unacceptable answer for anything for which there are old ways of doing it. Like instead of saying DSP-5 and BIS-748P, it would be export license application. A plain English description of what the application is...I had no idea that was funny. Anyway, but apparently I struck a nerve with that one. So of course this idea would still be constrained by the relevant statutes and the Arms Export Control Act and the broader policy purposes for the controls but it would basically be, the core instruction with every sentence and everything that the regulations contain is, what is the simplest, most clear way of describing what warrants control and why. It also would need to be something that would be understandable not only to U.S. companies but also to non-U.S. companies. The current regulations are not really written in such a way, taking into account, the significant export regulations that exist outside the regs. They of course would be consistent with our regime obligations. They wouldn’t be worded exactly the same way because we would need to implement perhaps in a more granular way. The numbering structures would align so that one could sort of see across both sets of controls what the words are, and it will be consistent with the structure of the various multilateral regimes. They would be, as I’ve described, internally consistent on key phrases and ideas. So it is largely an organizing effort, I mean a dramatic and substantial organization and rationalization effort and not meant to materially change the underlying policies. However it cannot be captive to simply doing it the way we’ve always done it because there will need to be small changes around the edges otherwise you end up with some of the things that happened with the very good rewrite in 1996 where it said absolutely no changes and you lock in for example outdated concepts that don’t make sense, you know like country group A:1, and for years it was just the list of the old COCOM countries and didn’t really for the last however many years reflect the countries that warranted A:1 treatment, the Wassenaar member group countries. We’ve since the fixed that by the way. So the drafter is also not the decision maker, the judgement and the ultimate decision still rests with each of the individual agencies through the regular interagency clearing process. But when drafting they need to take into account and keep in mind that the flaw in most regulatory structures including the export control regulations historically that require interagency clearance is that they are the lowest common denominator of what the relevant agencies and attorneys can agree to and so, as almost anything written by committee, it gets unnecessarily complex and layered with internal inconsistency. So this effort, for it to succeed, will need to be aware of that going in. Now I understand that export controls are inherently complex. You have as I described in previous years this fundamental tension between over control and a tailored set of regulations that are by definition more complex. So in this effort we need to take into account and be able to exercise the judgement about when to have a simple, broader scope of regulations that perhaps over controls when a tailored set may be more appropriate, and a good example of that is USML Category VIII (h) (1) which is a broader catch-all phrase which was done in a simpler over-controlled way for the sake of simplicity, and then XI (a) which is a much more tailored, specific set of controls. Anyway so I will just sort of tidy up this thought, and also a general rule is that if the same thought could be written with fewer words, then it should be written with fewer words. That’s just an idea, we are not going to be able to complete of course during this administration, but you all are Uber users of the export control system so I wanted to toss it out to you. Something to think about over time. Feel free to send in ideas as this idea develops within the U.S. government.

So let me switch from big picture ideas, to Export Administration. It is a terrific group of very smart and talented people. I am every day proud to work with them. They daily handle a massive number of very complex regulatory issues and policy issues and legal issues. The system is working. Albeit with the occasional hiccups which I am sure I will hear about, but that’s okay, we are here to fix them. The interagency referral system is working, the IT system is working, morale is good, but we are busier than ever as Eric mentioned. In percentage terms we’ve had a 68% increase in the volume of licensing activity in EA from this time to last year. What’s interesting about that is that the aggregate number of classification requests – this is a little surprising – other requests have stayed about the same. And what’s even more interesting and pleasant on a purely subjective basis, because you can’t quantify something like this, the number of disputes within the government and between industry and government with respect to topics that are the subject of classification requests is dramatically down. We haven’t had to have an Assistant Secretary-level meeting in almost two years to resolve – what used to be a monthly occurrence – to resolve disputes among the agencies on jurisdictional and classification issues. So whatever you think of "specially designed", and there are still more issues to work through, the data show it is radically reducing the number of disputes by and among and between companies in the industry. Yes there are always individual circumstances, Tim Moony and I and others will have a session on this to work through fact patterns, but it is working. By the way, please if you could stop so many as I call them ‘comfort letter requests,’ where what is clearly the case is that something either is on the CCL or not on the CCL. We will of course process them but if you are able to make a self-determination, please do so for your sake and for ours.

With respect to each of our offices: Exporter Services – Karen of course you met earlier and she is doing a terrific job at leading Exporter Services. Let me give you a couple of additional data points for what they are doing for the greater good. So the outreach programs in the aggregate have resulted in over a hundred thousand interactions with U.S. and foreign persons. They’ve conducted 350 events in total, including the weekly teleconferences, the Technical Advisory Committees, and as Eric described, they are focused largely on small and medium sized enterprises.

Since beginning the weekly teleconferences we’ve had a hundred and seventy one of them, and that have been heard, at least by those who have called in, by over 13,000 people. I don’t know how many, we just count each call-in as one, we don’t know how many people may be listening in on the same phone, so it’s probably even a little bit greater. We average 8 questions and answers per call for a total of 983 questions we’ve answered on those weekly calls. And as described, I will be doing an open version of that on Wednesday.

Cuba has been a major focus of our outreach efforts. We’ve conducted 17 events to describe the changes and then over the course of the rest of 2015 and 2016 there is a long list of other export control seminars and sessions that are going to be taking place around the country often in coordination with our friends at the Bureau of the Census and the Department of the Treasury. Up on our website soon will be an updated list of all the various sessions throughout the country over the course of this year and next. Don’t forget about our interactive tools that we’ve developed as part of the reform effort. We’ve got the CCL order of review, the specially designed on how to use license exception STA online decision try tools, just for the last year there were over 33,000 hits. We are about ready to roll out a de minimis licensing tool, I mean a decision tree tool, and we suspect that will be quite popular. Our call centers both in the Western Regional Office and here in DC have answered over 33,000 additional phone calls from you all about the regulations and the status of licenses and how you apply, etc. We’ve held 33 Technical Advisory Committee meetings. As you know we host 7 TACs as well as the PECSEA, all representative of industry and government participation to give us advice and to react to the various rules. This year we’ve added over 6,700 users to our SNAP-R system, now we have over 36,000 users of our licensing system.

Another office, SIES, Strategic Industries and Economic Security, is mentioned for a dramatic increase in the number of licenses that we’re handling and they are doing it quite well. They also are quite active in outreach and training on the defense trade side. They also handle our internal work with respect to the Committee on Foreign Investment in the United States and work closely with the Departments of Homeland Security and Defense on the DPAS regs in support of national defense programs. So thank you to Michael Vaccaro, if he hasn’t left already because of my home number reference that I made, but anyway he is doing a great job at leading that office.

OTE, the Office of Technology Evaluation, continues to provide data analytics to inform policy decisions with respect to, well, data, such as the Russian sanctions and the Cuba policy, and has been studying, on a really daily and monthly basis, trends with respect to the export control reform efforts so we don’t delude ourselves in what we are doing, that we actually have data in terms of who’s using what, and what’s going where, when. And in order to support the Secretary’s goal of data in her strategic plan, OTE has stood up a data portal on our website and will be demonstrating that in a room over there. They continue to work with CBP on export clearance issues including the Automated Export System and the Destination Control Statement and routed export rules in the post-departure filing process. They’ve partnered with the Export Management Compliance Division to educate exporters who inadvertently report AES transactions that are potentially noncompliant. They were instrumental in publishing the July 15thrule that sets out the policies and procedures for conducting surveys to obtain information to preform industry studies, to assess the health and effectiveness as various industries as a part of our industrial based work to support the national defense. They published a short report to better understand small businesses and the challenges facing these organizations in the U.S. space industry and they continue to work on a variety of assessments including one involving carbon fiber composite reports in June, and the printed circuit board industrial survey assessment. Thanks to Gerry Horner for his terrific work in leading that group.

Our office of National Security and Technology Transfer group is ably lead by Eileen doing a terrific job with a wide variety of topics. This office is the point for our Wassenaar work and they are doing a terrific job. Just to give you an example, for this year, 23 out of 24 of its proposals were accepted. And this work is really quite critical to ensuring that our dual-use controls are properly calibrated and updated. This office is also the point with respect to the fast moving and very complex issues involving the Russia sanctions. It is also doing its best to do what it can do be creative in terms of making us more user friendly, in the encryption rules and the license exceptions. Little known is that it is also the part of our office, our bureau that takes the lead with respect to handling issues involving crude oil exports. And it’s also the office that is responsible for the new controls on commercial satellites and spacecraft that have moved over from the State Department. And that is a really terrific ECR success story. The data and the anecdotes that we hear from industry about sales that otherwise wouldn’t have occurred and the reduction of burden and the efficiency of the licensing process on the commercial satellite and spacecraft related activities is really, really terrific.

The Office of Nonproliferation and Treaty Compliance is well led by Alex who is doing a great job there, Alex Lopes, and you know he shepherds our Nuclear Supplier’s Group, Missile Technology Control Regime, and Australia Group regime efforts. Those are of course really quite critical to the reason export controls exist, to stem proliferation with respect of these items. They are doing a lot of work these days to expand their membership and to expand compliance norms and nonproliferation norms around the world and always looking for ways in which those objectives can be handled more simply. The office’s Treaty Compliance Division continues to play a leading role in ensuring the U.S. meets it obligations under the Chemical Weapons Convention. In the past year, for example, it collected 771 declaration reports from 548 facilities and trading companies, and took part in the OCPW inspection of 16 chemical plant sites, successfully demonstrating our compliance with those obligations. The successful destruction by a U.S. company of precursor chemicals retrieved from the Syrian chemical weapons program and verification of this destruction by the OPCW was a signature success due in large part to help from this group. And our Foreign Policy Division in this office has played a prominent role in developing and working through our policies regarding Iran and Cuba that Eric described.

So let me just finish up there, I want to give special thanks to my deputy director, Matt Borman, who is the best leader in all of BIS, the rock of EA. Kathleen, Steve, Bob and Darryl in my front office for making things run so efficiently and for handling not just the process but the substance of multiple issues. You are very good at what you do and make EA and BIS proud. Thanks to Mi-Young Kim and Eric Longnecker for shepherding our Operating Committee, trying to resolve interagency disputes on license determinations, trust me is not easy. Eric finished after a long stance and Mi-Young has taken over and they’ve both done a terrific job. Thanks to Joe Cristoforo who is doing a terrific job at shepherding our End User Review Committee and the VEU program and then also special thanks of course to our Counsel and OCC for always providing really quality, practical, useful legal advice and our friends down the hall in Export Enforcement where we work hand in glove on all issues. So anyway, thanks for being here, enjoy the conference, do well, learn, give advice, find that elusive 6th export control joke, export, learn the regs, export some more, and comply. So thank you very much.

   
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