1. Export Compliance at Fluke
11/12/2018
EXPORT COMPLIANCE
KEEPING OUR WORLD UP AND RUNNING
Carol Mikula
Export Compliance Coordinator
Phone:
Cathleen Bouvart
Phone:
December 8, 2009
Company Confidential
Export Compliance at Fluke

2. Export Compliance at Fluke
11/12/2018
EXPORT COMPLIANCE
AGENDA:
Corporate Compliance Policy Statement
Reasons for Controls
The cost of violations
U.S. Export Control review
What an export transaction is
Questions
December 8, 2009
Company Confidential
Export Compliance at Fluke

3. FLUKE CORPORATE COMPLIANCE POLICY
11/12/2018
FLUKE CORPORATE COMPLIANCE POLICY
Adhere strictly to all applicable export control laws and regulations
Train employees
Maintain an internal control program
Disclose known violations
Our policy at Fluke is to Adhere strictly to all applicable export control laws and regulations.
We will train employees through presentations such as this. Danaher also offers Import/Export regulations web based training programs. Any one directly related with the Import or Export process at Fluke companies are required to take this series of classes.
We will maintain an internal control program through audits.
We will disclose any known violations. This is done in hopes of avoiding huge fines or penalties. If you do not report a known violation and you are caught by Export Enforcement, you are viewed as trying to hide a violation.
CARRY OUT NO TRANSACTION IN VIOLATION OF THE LAW
December 8, 2009
Company Confidential
Export Compliance at Fluke

4. 11/12/2018
REASONS FOR CONTROLS
Protect National Security from Military Threats and Acts of Terrorism
Promote Foreign Policy
Preserve Domestic Availability of Products in Short Supply
Prevent Proliferation of Weapons of Mass Destruction
Dual-Use products have civilian and military applications
12 November 2018

5. Export Compliance at Fluke
11/12/2018
THE COST OF VIOLATION
Civil Penalties in the form of fines
Criminal Penalties resulting in imprisonment
Loss of Export Privileges
U.S. Commerce Department along with U.S. Customs and Border Protection, have significantly increased their enforcement of the export regulations
December 8, 2009
Company Confidential
Export Compliance at Fluke

6. Export Compliance at Fluke
11/12/2018
EXPORT TRANSACTIONS
Any item that is sent from the United States to a foreign destination is an export.
A deemed export is a “release” of technology, software, or source code to a Foreign National in the United States
Technology is “released” for export
when it is available to a foreign national for visual inspection – example - reading technical specifications
When technology is exchanged orally
When technology is made available by practice or application under the guidance of persons with knowledge of the technology
December 8, 2009
Company Confidential
Export Compliance at Fluke

7. Export Compliance at Fluke
11/12/2018
EXPORT TRANSACTIONS
Transfer of Product from U.S
For Sale or No Charge Transactions
Shipment or Hand Carry
Temporary Use
Demo or Exhibition
Servicing and Repair
Hiring and training of foreign nationals
Training, lectures, seminars
Re-export from original destination A
December 8, 2009
Company Confidential
Export Compliance at Fluke

8. Export Compliance at Fluke
11/12/2018
U.S. EXPORT CONTROLS
NO Fluke product may be exported or re-exported to:
Cuba, Iran, North Korea, Sudan, or Syria
The U.S. maintains an embargo on Cuba and North Korea. No products, regardless of origin, ay be exported to these two countries.
For Iran, Sudan or Syria, No products made in the U.S. or exported from the U.S. may be exported or re-exported to these countries.
The rules for Iraq have changed. We now can ship goods to Iraq, however, if the product requires a license to ship to Iraq, then any transfer within Iraq
December 8, 2009
Company Confidential
Export Compliance at Fluke

9. Export Regulations for Fluke’s Thermal Imaging Cameras
11/12/2018
Export Regulations for Fluke’s Thermal Imaging Cameras
The Fluke Thermal Imager is controlled by the Bureau of Industry and Security United States Department of Commerce, diversion of this product contrary to U.S. law prohibited.
An export license must be obtained from the Bureau of Industry and Security, United States Department of Commerce before leaving the United States or Canada. Failure to do so is in violation of the Export Administration Regulations
December 8, 2009
Company Confidential
Export Compliance at Fluke

10. Export Compliance at Fluke
11/12/2018
U.S. EXPORT CONTROLS
Denied Persons List (DPL)
Violators of U.S. export regulations denied export privileges by the U.S. Government
Specially Designated Nationals (SDN)
Parties identified by the U.S. as acting on behalf of embargoed countries
Subject to same controls as an embargoed country
ENTITY LIST
Parties identified for known involvement in prohibited end use
U.S. export license required for ALL transactions
Currently includes parties in: Canada, China, Egypt, Germany, Hong Kong, India, Iran, Israel, Kuwait, Lebanon, Malaysia, Pakistan, Russia, Singapore, South Korea, Syria, and the U.A.E.
December 8, 2009
Company Confidential
Export Compliance at Fluke

11. Export Compliance at Fluke
Know Your Customers!!!!
Look for diversion possibilities or “Red Flags”
Customer is evasive or unclear if the shipment is for domestic or foreign use
Unusual ship to location or shipment to a freight forwarder
Product does not match the customers line of business
The customer or purchasing agent is reluctant to offer information about the end-use of the item
The customer is willing to pay cash for a very expensive item
The customer has little or no business background
The customer is unfamiliar with the product's performance characteristics but still wants the product
Routine installation, training, or maintenance services are declined by the customer
December 8, 2009
Company Confidential
Export Compliance at Fluke

12. CONTACTS AND REFERENCES
Fluke contacts for questions regarding regulations on Fluke products are:
Carol Mikula at or phone , fax
Cathleen Bouvart at or phone , fax
Denied parties search:
You may also refer to for more details on the US Export Rules and Regulations
Note: Fluke does not endorse Visual Compliance, this is only a recommendation of one of the many services available.
December 8, 2009
Company Confidential
Export Compliance at Fluke

13. Export Compliance at Fluke
11/12/2018
SUMMARY
Fluke products are controlled by the U.S. Department of Commerce export laws and regulations
Fluke maintains a strict export compliance program
Violations may result in costly penalties, including loss of export privileges
Watch closely for the “Red Flag” indicators
Know your customers!!
Compliance is the responsibility of everyone
QUESTIONS?
December 8, 2009
Company Confidential
Export Compliance at Fluke

14. Export Compliance at Fluke
11/12/2018
EXPORT COMPLIANCE
KEEPING OUR WORLD UP AND RUNNING
Fluke Export Compliance Team:
Carol Mikula
Cathleen Bouvart
December 8, 2009
Company Confidential
Export Compliance at Fluke