The STA Compliance Checker automatically determines whether an item is eligible for License Exception STA (§ 740.20 of the EAR) and if the compliance requirements are met accordingly. It streamlines the assessment of pre-defined criteria and provides guidance on how to apply for the license, if an item proves to be eligible, while maintaining a full audit trail to satisfy the strict transparency requirements of the U.S. Department of Commerce, Bureau of Industry and Security (BIS).
The tool replaces the need to manually assess individual export items against license criteria, which is an otherwise onerous and time-consuming task. The open architecture of the tool allows it to be adjusted to cover every instance of a company’s bespoke export policies. Its modular logic can easily be edited to accommodate changing laws and additional requirements from the BIS.

Background

As part of the ongoing Export Control Reform, the license exception Strategic Trade Authorization (STA) allows controlled items to be exported without a transaction-specific license. To confirm whether an item is eligible under this authorization, parties have to meet defined conditions as laid out by § 740.20 of the EAR, the assessment of which can be an onerous and time-consuming task. In addition, a detailed audit trail of individual assessments is required to fulfill the transparency requirements of the U.S. Department of Commerce, Bureau of Industry and Security (BIS).

With BRYTER, companies can build an automated STA Compliance Checker which assesses whether an item is eligible for the STA government exception. The tool guides users through a series of questions regarding the specifications of the export items, details regarding the place of origin and destination, as well as transparency criteria. The inputs trigger underlying logic that determines whether the item is eligible and whether the compliance requirements are met. As a final output, the user receives a full report of the assessment and receives guidance relating to any necessary next steps. Due to the open architecture of the BRYTER platform, the tool’s modular logic can easily be amended to ensure its compliance with changing legal requirements.

Benefits

Automated & standardized

The STA Compliance Checker allows companies to assess export items against STA criteria through a standardized process. This ensures a consistent approach and documentation.

Integrated

The STA Compliance Checker can easily be integrated into an existing IT infrastructure so that results can, for example, be written back into existing databases.

Centralized audit trail

As part of the tool, compliance with the defined conditions of the STA is tracked and documented in a centralized audit trail. This allows users to document and produce proof of compliant behavior as and when needed for the BIS.

Faster Execution

The STA Compliance Checker is available 24/7 and streamlines an otherwise time-consuming assessment to ensure faster execution.

Highly customizable

As every application built on BRYTER is customizable the STA Compliance Checker may accommodate a company’s unique policies, processes and STA requirements.

How it works

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Go through Q&A

Through a customizable and user-friendly questionnaire, all relevant information such as the type of item and details of the export destination, is gathered from the user. The inputs then determine which logic is applied to provide an assessment.

Receive assessment

A full assessment report of the item’s eligibility for STA is generated, based on the provided information. As the tool is used, a full audit trail is maintained to document and provide proof of any assessments and their results.

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Keep up-to-date

The open architecture of the BRYTER platform allows the application to be updated continuously in the background, ensuring that the results are always compliant with the requirements of the BIS.