Export Compliance Officer | Questions & Verified Answers |
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Section 1: EAR Fundamentals & Jurisdiction (Questions 1-15)
Q1: Under the Export Administration Regulations (EAR), which of the following actions
constitutes an "export" as defined in 15 CFR 734.14?
A. A domestic sale of a US-origin commodity between two US companies in California
B. Sending a controlled commodity from the United States to Canada
C. Releasing technology to a US citizen employed by a foreign company in the United
States
D. Importing a foreign-made commodity into the United States for domestic
consumption
Correct Answer: B
Rationale: Under 15 CFR 734.14, an export includes sending or taking an item out of the
United States. Option A is a domestic transaction, C involves a US person (no export),
and D is an import.
Q2: Which agency has primary jurisdiction over the Export Administration Regulations
(EAR) codified in 15 CFR 730-774?
A. Department of State Directorate of Defense Trade Controls (DDTC)
B. Department of Commerce Bureau of Industry and Security (BIS)
C. Department of Treasury Office of Foreign Assets Control (OFAC)
D. Department of Homeland Security Customs and Border Protection (CBP)
Correct Answer: B
Rationale: BIS administers the EAR. DDTC administers ITAR (22 CFR 120-130), OFAC
administers sanctions, and CBP enforces customs and border aspects.
Q3: A German company manufactures industrial equipment incorporating US-origin
components constituting 12% of the finished product's value. The equipment is sold to
Brazil. Under the EAR de minimis rule in 15 CFR 734.4, which statement is correct?
A. The equipment is subject to the EAR because any US-origin content triggers EAR
jurisdiction
,B. The equipment is not subject to the EAR because the US-controlled content is less
than 25% by value
C. The equipment is subject to the EAR because Brazil requires a license for all
US-origin items
D. The equipment is not subject to the EAR because the components are merely
incorporated and not modified
Correct Answer: B
Rationale: Under the de minimis rule, foreign-made items with less than 25%
US-controlled content by value are generally not subject to the EAR when destined to
most countries (excluding embargoed destinations). Brazil is not embargoed.
Q4: Under the EAR General Prohibitions in 15 CFR 736, which prohibition applies to the
reexport of US-origin items from one foreign country to another?
A. General Prohibition One
B. General Prohibition Two
C. General Prohibition Four
D. General Prohibition Six
Correct Answer: B
Rationale: General Prohibition Two (15 CFR 736.2(b)(2)) prohibits the reexport of
US-origin items to another foreign country without a license if required.
Q5: A US company exports controlled technology to its subsidiary in France. The French
subsidiary subsequently provides that same US-origin technology to a customer in
Russia. Which EAR General Prohibition is most directly implicated?
A. General Prohibition One
B. General Prohibition Two
C. General Prohibition Three
D. General Prohibition Six
Correct Answer: B
Rationale: General Prohibition Two covers the reexport of US-origin technology from one
foreign country to another. While Russia may also trigger GP Six, GP Two is the direct
prohibition for reexport of US-origin items.
Q6: Which of the following scenarios violates General Prohibition Ten under 15 CFR
736.2(b)(10)?
A. Exporting EAR99 items to a customer in Canada without a license
,B. Proceeding with a transaction after receiving an official notification from BIS that the
export is prohibited
C. Shipping items under License Exception LVS to a Country Group B destination
D. Filing AES documentation three days after the date of export
Correct Answer: B
Rationale: General Prohibition Ten prohibits proceeding with transactions with
knowledge that a violation has occurred or is about to occur, including after receiving
official BIS notification.
Q7: An item is subject to the EAR but does not appear on the Commerce Control List
(CCL). How is this item classified for export control purposes?
A. It is classified as EAR99
B. It requires a Commodity Classification request to BIS
C. It is automatically controlled for Anti-Terrorism reasons only
D. It cannot be exported without an individual validated license
Correct Answer: A
Rationale: Items subject to the EAR but not listed on the CCL are classified as EAR99.
They do not require a license unless destined for a prohibited end-user, end-use, or
embargoed country.
Q8: Under 15 CFR Part 762, how long must an exporter retain records relating to export
transactions?
A. Three years from the date of export
B. Five years from the date of export
C. Seven years from the date of export
D. Ten years from the date of export
Correct Answer: B
Rationale: EAR Part 762 requires exporters to maintain records for five years from the
date of the transaction.
Q9: Under the EAR, which of the following is NOT considered a "U.S. person"?
A. A US citizen permanently residing in the United States
B. A lawful permanent resident of the United States (Green Card holder)
C. A foreign national temporarily in the United States on an H-1B visa
D. A corporation organized under the laws of the State of Delaware
Correct Answer: C
, Rationale: Under the EAR, a US person includes citizens, permanent residents, protected
individuals, and US-organized entities. A foreign national on an H-1B visa is not a US
person.
Q10: A prospective customer in Dubai places an order for high-precision machine tools.
During due diligence, the compliance officer notices the customer's requested shipping
address is a freight forwarder in the UAE, but the end-user statement lists a company in
Iran. The customer insists the tools are for domestic UAE use. What is the most
appropriate compliance response?
A. Process the order under License Exception GBS since the UAE is in Country Group B
B. File the shipment under EAR99 and proceed with the freight forwarder address
C. Refuse the order and file a report with BIS because the transaction presents red flags
of a potential diversion to Iran
D. Request a Commodity Classification from BIS before making any decision
Correct Answer: C
Rationale: A freight forwarder address inconsistent with the stated end user, combined
with a link to Iran, is a classic red flag for diversion. The appropriate response is to halt
the transaction and report to BIS.
Q11: A US manufacturer produces a ruggedized laptop computer with enhanced
encryption and thermal management originally developed under a Department of
Defense contract. The manufacturer is uncertain whether the laptop is controlled under
the EAR or ITAR. Which procedure should the manufacturer follow?
A. File a self-classification report with BIS using ECCN 5A002
B. Submit a Commodity Jurisdiction (CJ) request to DDTC under 22 CFR 120.4
C. Submit a Commodity Classification (CCATS) request to BIS under 15 CFR 748.3
D. Register with DDTC and apply for a DSP-5 license as a defense article
Correct Answer: B
Rationale: When there is uncertainty whether an item is a defense article (ITAR) or
dual-use item (EAR), a Commodity Jurisdiction request to DDTC is the proper procedure
to determine jurisdiction.
Q12: Under the EAR de minimis rule in 15 CFR 734.4, what is the general threshold
percentage of US-controlled content below which a foreign-made item is not subject to
the EAR when destined to most countries?
A. 5%