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Section 1: Regulatory Framework - EAR, ITAR, OFAC (Questions 1-20)
Q1: Which U.S. government agency administers the Export Administration Regulations
(EAR)?
A. Department of State, Directorate of Defense Trade Controls (DDTC)
B. Department of Commerce, Bureau of Industry and Security (BIS) [CORRECT]
C. Department of Treasury, Office of Foreign Assets Control (OFAC)
D. Department of Homeland Security, Customs and Border Protection (CBP)
Correct Answer: B
Rationale: The Bureau of Industry and Security (BIS) within the Department of
Commerce administers the EAR under 15 CFR Parts 730-774. DDTC administers ITAR
(22 CFR 120-130), OFAC administers sanctions programs (31 CFR), and CBP enforces
customs and border regulations but does not administer export control regulations.
Q2: Under the ITAR, which of the following activities requires registration with DDTC
before engaging in such activity?
A. Exporting EAR99 commercial items to Canada
B. Manufacturing defense articles or providing defense services to foreign persons
[CORRECT]
C. Importing consumer electronics from Country Group A:1 nations
D. Filing Electronic Export Information (EEI) in the Automated Export System
Correct Answer: B
,Rationale: ITAR § 122.1(a) requires any person who manufactures, exports, or
temporarily imports defense articles or furnishes defense services to register with
DDTC. Exporting EAR99 items, importing consumer electronics, and filing EEI are not
ITAR registration triggers.
Q3: Which regulatory framework governs U.S. economic sanctions and embargoes
against targeted countries, entities, and individuals?
A. Export Administration Regulations (EAR)
B. International Traffic in Arms Regulations (ITAR)
C. OFAC regulations under 31 CFR [CORRECT]
D. Foreign Trade Regulations (FTR)
Correct Answer: C
Rationale: OFAC regulations under 31 CFR administer economic sanctions and trade
embargoes. The EAR governs dual-use exports, ITAR governs defense articles/services,
and FTR governs export documentation requirements.
Q4: A company discovers it has been shipping EAR-controlled items to an entity on the
BIS Entity List without obtaining the required licenses. Which agency has primary
enforcement jurisdiction over this violation?
A. Department of State, DDTC
B. Department of Commerce, BIS Office of Export Enforcement (OEE) [CORRECT]
C. Department of Justice, FBI Counterintelligence Division only
D. Department of Treasury, OFAC
Correct Answer: B
Rationale: BIS Office of Export Enforcement (OEE) has primary jurisdiction over EAR
violations. DDTC enforces ITAR, OFAC enforces sanctions, and while DOJ may
prosecute criminal violations, BIS OEE leads civil enforcement for EAR violations.
Q5: Under the EAR, what is the definition of an "export"?
A. Only the physical shipment of goods outside the United States
,B. The actual shipment or transmission of items out of the U.S., or release of
technology/source code to a foreign person in the U.S. [CORRECT]
C. Any financial transaction with a foreign entity
D. Only the transfer of defense articles to foreign governments
Correct Answer: B
Rationale: EAR § 734.14 defines export to include both actual shipment/transmission of
items subject to the EAR out of the U.S. and release of technology or source code to a
foreign person in the U.S. (deemed export). Financial transactions and defense articles
are not part of this definition.
Q6: Which of the following countries was REMOVED from the ITAR § 126.1 list of
proscribed destinations in November 2025?
A. Syria
B. Cambodia [CORRECT]
C. Belarus
D. Venezuela
Correct Answer: B
Rationale: Effective November 7, 2025, Cambodia was removed from ITAR § 126.1 in
recognition of its efforts toward peace, security, and defense cooperation. Syria,
Belarus, and Venezuela remain on the proscribed destinations list.
Q7: The BIS Affiliates Rule, effective September 29, 2025, extends restrictions to entities
owned what percentage or more by listed parties on the Entity List or MEU List?
A. 25%
B. 33%
C. 50% [CORRECT]
D. 75%
Correct Answer: C
, Rationale: The BIS Affiliates Rule extends Entity List and Military End-User List
restrictions to foreign entities owned 50% or more, directly or indirectly, by one or more
listed entities. This is modeled on OFAC's 50 Percent Rule.
Q8: Which of the following is TRUE regarding the ITAR registration fee structure
effective January 9, 2025?
A. Tier 1 registrants pay $2,250 annually
B. Tier 2 registrants with 5 or fewer approvals pay $4,000 [CORRECT]
C. Tier 3 registrants pay a flat fee of $2,750
D. All tiers pay the same flat fee regardless of licensing activity
Correct Answer: B
Rationale: Effective January 9, 2025, Tier 2 registrants (those with 5 or fewer favorable
determinations) pay $4,000. Tier 1 is $3,000 (or $2,500 with discount), and Tier 3 is
calculated as $4,000 plus $1,100 per approval over 5.
Q9: Under OFAC regulations, which of the following activities is PROHIBITED without
specific authorization?
A. Exporting EAR99 items to Canada
B. Dealing in property or interests in property of Specially Designated Nationals (SDNs)
[CORRECT]
C. Shipping goods under License Exception TMP
D. Filing voluntary self-disclosures with BIS
Correct Answer: B
Rationale: OFAC 31 CFR § 501 prohibits U.S. persons from engaging in transactions
involving property or interests in property of SDNs unless authorized by general or
specific license. Exporting to Canada, using TMP, and filing VSDs are not
OFAC-prohibited activities.
Q10: Which Executive Order revoked comprehensive OFAC sanctions on Syria, effective
July 1, 2025?