The U.S. Commerce Department's Bureau of Industry and
Security (BIS) recently issued a reminder to the industry regarding
export requirements. This reminder, titled "Don't Let This
Happen to You," includes examples of significant enforcement
actions resulting from failure to follow export control
regulations, including enforcement of regulations concerning
"deemed exports."
The BIS implements the Commerce Department's Export
Administration Regulations (EAR), and leads federal efforts
controlling exports of a wide range of goods and technology,
including some "balance of plant" components and
technology at nuclear power plants. Generally, the U.S. Nuclear
Regulatory Commission (NRC) regulates the export of nuclear
material and reactor components, while the U.S. Department of
Energy (DOE) regulates the export of nonpublic information and
technology related to uranium enrichment and the "nuclear
island." We have noted increases in attention to export
controls by both
