CPI Investigations

Question 1

How long can you detain something pending further investigation to get a license determination?

Answer 1

As long as necessary.

Question 2

The Electronic Export Information (EEI) must be filled within how many hours prior to an export?

Answer 2

24 hours

Question 3

When is Electronic Export Information (EEI) normally required?

Answer 3

When the shipment is over $2,500.

Question 4

What do you put in a PSA ROI?

Answer 4

Location, what you told them, who was there (present)

Question 5

What do you use to deconflict all leads?

Answer 5

The Export Enforcement Coordination Center (E2C2)

Question 6

Who is the POC for all licensing jurisdiction request?

Answer 6

Exodus Command Center (ECC)

Question 7

Whats the denied persons list?

Answer 7

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.

Question 8

What are the elements 22 USC 2278 Control of Arms Exports and Imports?

Answer 8

• 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

Question 9

What are the presidential authorities per IEEPA?

Answer 9

• 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

Question 10

What are the elements of a violation of IEEPA regulations?

Answer 10

• Knowing and willful
• Covered transfer, export, import, travel transaction, or contract performance
• Without U.S authorization

Question 11

What is 18 USC 554 (outbound smuggling section)?

Answer 11

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.

Question 12

What is USML?

Answer 12

Its a list showing what items require a license for exporting and brokering activities. (single use items, for military only.

Question 13

What is CCL?

Answer 13

Commerce Control list for most commercial and dual use items that require a export license under the Export Administration Act of 1979 (EAA)

Question 14

What is CPI most important priority?

Answer 14

Interdiction.
Stop the illegal export from reaching its destination due to national security implications. Interdiction of export over arrest-prosecution s secondary.

Question 15

How do you obtain license determination?

Answer 15

Agents must submit request to the ECC through the Exodus Accountability and Referral System (EARS)

Question 16

What are the three types of CPI investigations?

Answer 16

Proactive
Reactive
Historical

Question 17

what is transshipment?

Answer 17

For purpose of giving an illegal export the appearance of legitimacy, shipping a commodity from the U.S.

Question 18

How do you prove specific intent?

Answer 18

• 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

Question 19

Whats “Deemed Exports” (intangible transfer)?

Answer 19

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.