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Amsterdam, Netherlands

October 20, 2025

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Take the mystery out of U.S. export rules with training specifically for non-U.S. companies.

U.S. export regulations can affect activities of companies outside the United States in ways that often seem confusing and arbitrary. ECTI training for non-U.S. companies helps new and experienced compliance professionals alike to understand when their activities intersect with U.S. export controls, and how to navigate them.

Our expert instructors have decades of experience working with all U.S. export regimes – including Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR) and Office of Foreign Assets Controls & Embargoes – as they apply to non-U.S. companies and affiliates that use, resell or reexport American products, technologies or services.

Our training seminars are appropriate for all export-related job functions at non-U.S. companies as well as affiliates of U.S. companies located outside the United States.

Registration Options

ITAR Controls Seminar

October 20-21, 2025

View Agenda

ECoP® ITAR renewal credits = 4

USD $2,285.00
(Inclusive of 21% VAT)

EAR/OFAC Controls Seminar

October 22-23, 2025

View Agenda

ECoP® EAR renewal credits = 4

USD $2,285.00
(Inclusive of 21% VAT)

BOTH Seminars

October 20-23, 2025

SAVE $440 when you attend both!

ECoP® ITAR/EAR renewal credits = 4 each

USD $4,130.00
(Inclusive of 21% VAT)

By registering for this event, you agree to our Terms of Use and Seminar Policies.

Meet Our Instructors

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Scott Gearity

Principal Consultant – Trade Controls Consulting

Scott Gearity brings nearly 20 years of consulting, training, and corporate export compliance program management experience to bear for his clients. Mr. Gearity has substantial experience in military, dual-use, and commercial export controls.

View Scott's bio.

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Johanna Reeves

Founding Partner – Reeves & Dola, LLP

Johanna Reeves is a founding partner of the Washington, DC law firm, Reeves & Dola, LLP. For 20 years, Ms. Reeves has dedicated her practice to advising U.S. companies on export and import matters.

View Johanna's bio.

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Guest Speaker

Stephan Müller

Partner – Oppenhoff & Partner

Stephan Müller heads the Oppenhoff firm’s public law practice group (which focuses on foreign trade law as well as environmental, public procurement and antitrust law). 

View Stephan's bio.

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Why should I attend?

The ability to navigate the relevant regulations is a valuable specialty that offers these benefits to you and your non-U.S. organization:

  • Better understanding of requirements around reselling and reexporting U.S. content
  • Improved navigation of U.S. export laws and documentation
  • Faster identification of requirements for specific products, services and technologies
  • Updated knowledge on changes in the rules that affect you
  • Shortened approval timelines
  • Reduced risk of costly complications that can delay transactions and raise red flags for regulators
  • Enhanced reputation among trading partners
  • Competitive advantage in trade with U.S. entities and around the world
  • Increased supply chain security

Seminar Schedule & Agendas

ECTI Seminars include daily continental breakfast, lunch, and snack breaks. 

9:00 AM – 12:00 PM

12:00 PM – 1:00 PM

1:00 PM – 5:00 PM

ITAR Controls on Non-U.S. Transactions Agenda

Export Controls Overview

  • Overview of U.S. Export Controls; What is Subject to Export Controls?
  • Primary Regulations (ITAR/EAR/OFAC)
  • International Export Regulation 
  • Introduction to the International Traffic in Arms Regulations (ITAR) & Defense Trade Policy
  • Directorate of Defense Trade Controls (DDTC)
  • Arms Export Control Act (AECA)
  • Compliance Resources & Information

Controlled Items & Activities

– with EXERCISES WORKSHOP

  • Key Analysis Steps for ITAR Compliance / When the ITAR Applies
  • ITAR-Controlled Items
    • Defense Articles; Technical Data and What is not Technical Data; Defense Services
    • United States Munitions List (USML) & Identifying ITAR vs. EAR-Controlled Items
    • Order of Review
    • The Meaning of “Specially Designed”
  • Controls on Non-U.S. Items Containing U.S. Content
  • Controls on Non-U.S. Items Produced Using U.S. Technology
  • Commodity Jurisdiction (CJ) Requests, Issues, and Resources
  • Highly Restricted Items and Significant Military Equipment (SME)
  • ITAR-Controlled Activities: Exports, Reexports & Retransfers
  • Name Changes, Mergers & Acquisitions, Brokering / Manufacturing of Defense Articles Outside the U.S.
  • Temporary Imports / Permanent Imports
  • Activities Not Regulated by the ITAR
  • Prohibited Countries & Debarred Parties

Licenses

  • Types of DDTC Licenses
  • Supporting the U.S. Exporter’s Licensing Efforts
  • Supporting Documents for Hardware Licenses
  • Application Package
  • Reexport/Retransfer Approvals for Non-U.S. Companies

Reexport/Retransfer License

  • Reexport/Retransfer License Applications
  • Foreign Military Sales (FMS) Third Party Transfers

Agreements and U.S. Government Approval

  • Types of DDTC Agreements: Manufacturing License Agreements  Technical Assistance Agreements, & Warehouse and Distribution Agreements
  • Agreement Structure
  • Agreement Application & Agreement Guidelines
  • TAA and MLA Issues and Requirements, Handling Hardware in Agreements
  • Sublicensing, Sublicensing vs. Signatory
  • Dual/Third Country National Employees and Provisions for NATO+
  • Australia/Canada/Netherlands 3rd/Dual Nationals
  • Foreign Persons Coverage on Agreements
  • Information that a Non-US Party Should Provide to US Agreement Applicant
  • Warehouse & Distribution Agreements / How Does The US Exporter Get a WDA Approved?

U.S. Government Approval

– with EXERCISES WORKSHOP

  • Information Non-US Parties Should Request After Agreement Approval
  • Agreement Amendments / Application Processing Issues
  • U.S. Government Review Process
  • Congressional Notification / Processing Times
  • Expedited Licensing Programs
  • Checking License Status
  • End-Use Checks

Exemptions

– with EXERCISES WORKSHOP

  • Exemptions Available to U.S. Exporters
  • Foreign Military Sales / Allies Maintenance Exemption
  • Tech Data Exemptions for US Exports
  • NATO+ Reexport or Retransfer Exemption
  • Exemption for Reexports to Dual and Third Country National Employees of Non-U.S. Entities
  • Basic Marketing Information Exclusions and Public Domain 
  • Country-Based Exemptions: Australia, Canada and the United Kingdom

Special Issues

  • Exporting Defense Articles to the U.S.
    • Permanent and Temporary Imports into the U.S. (Including Repairs)
  • What to Do If Exemptions are Not Available?
  • Return of Items Received From the U.S. Under DSP-73
  • Procurement in the U.S.

Brokering

  • “Who is a Broker?”; Brokering Activities and Exclusions From These Activities
  • Registration, What Requires Approval, Exemptions, Exemption Exclusions & Reporting

Political Contributions, Fees & Commissions

– with EXERCISES WORKSHOP

  • Threshold and Reporting Requirements
  • Defining Applicants, Suppliers & Vendors
  • Supplemental Reports

Compliance Programs

  • Key Elements, Considerations & Procedural Approaches
  • ICP Procedure Priorities for Companies Outside the U.S.
  • Compliance Training / Automation / ICP Guidance and Tips
  • Risk Assessment & U.S. Government Program Recommendations

Recent Developments

  • Latest Regulatory Changes
  • Other Recent Developments in the ITAR

ITAR Export Enforcement

  • Enforcement Agencies & Methods
  • Common ITAR violations
  • Fines & Penalties, Possible Outcomes in ITAR Penalty Cases
  • Additional, Informal “Sanctions”
  • When Violations are Discovered / Voluntary Disclosures
  • Trends in Enforcement
  • Enforcement Case Studies

 

*Timing and Order of agenda items subject to change

EAR/OFAC Controls on Non-U.S. Transactions Agenda

Introduction to the Export Administration Regulations

  • U.S. Export Control Policies & Key Control Concepts
  • Comparison to International Regime
  • Why Should a Non-U.S. Company Comply?
  • What is Subject to Export Controls? Commodities, Software, Technology/Technical Data
  • Regulated Activities: Exports, Reexports, Transfers, Deemed Exports and Reexports, U.S. Person Activities
  • Primary U.S. Export Control Regulations
    • International Traffic in Arms Regulations (ITAR)
    • Export Administration Regulations (EAR)
    • Office of Foreign Assets Control (OFAC) Sanctions Regulations
  • Extraterritoriality of Rules

EAR Controls

  • STEP 1: Who Are You? How U.S. Rules Apply to Non-U.S. Companies and Non-U.S. Persons
    • Controls on U.S. Persons & U.S. Subsidiary Activities
  • STEP 2: Sensitive U.S. Content Always Subject to Controls
    • Introduction to Foreign Direct Products of U.S. Technology
    • 600-Series and 9X515 ECCNs Sensitive Content
    • United States Munitions List (USML) Content
  • STEP 3: U.S. Content De Minimis Rules
    • De Minimis Rules for Hardware & Software
    • Rule of Second Incorporation
    • What is a Discrete Product for 2nd Incorporation?
    • De Minimis Rules: Software With or in Hardware
    • Software Bundling & Technology Reports
    • Foreign Direct Product Rules: National Security, 9x515, 600 Series
  • STEP 4: Export Control Classification
    • Jurisdiction: Which Agency Has Authority?
    • EAR, Commerce Control List
    • Order of Review and Structure of ECCNs
    • Defining “Specially Designed,” The (b) Releases and Implications
    • How to Read ECCNs
    • ECCN Classification Tips and Understanding EAR99
    • Requesting an Official Classification
    • Working with U.S. Suppliers for Classifications
    • EAR Controls on Non-U.S. Military Items
  • Technology & Software Classification
    • Defining Technology / Reexport of Technology and Source Code
    • Reexport Examples of Technology and Software 
    • Technology and Software Classification
    • Items Not Subject to the EAR, “Published” Software & Technology
    • Determining the ECCN of Technology and Software
  • STEP 5: “No License Required” Determination – with EXERCISES WORKSHOP
    • Steps to Arrive to NLR Determination
    • Using the Commerce Country Chart to Guide in Determination
    • NLR with an Example / EAR99 and NLR
  • STEP 6: License Exceptions
    • Two Types of License Exceptions
    • Country Groups / Restrictions on License Exceptions
    • ECCN-based License Exceptions (GBS, LVS, STA )
    • Situation-based License Exceptions (RPL, TMP, GOV, APR)
    • Technology & Software License Exceptions (TSU, TSR, ENC, TMP)
    • Foreign Direct Products / Controlled US Content & De Minimis (Reviews from Step 2 and 3)
  • STEP 7: End-Use and End-User Controls – with EXERCISES WORKSHOP
    • Restricted Parties; Embargoed Countries; Proliferation Activities
    • Military End-Use/User Rule (Belarus, Burma, Cambodia, China, Nicaragua, Russia, & Venezuela
    • Other Military End-Use/User Restrictions
    • Red Flags, General Prohibitions, Antiboycott
    • Applying for a Bureau of Industry & Security License
    • Reasons for Applying for a License
    • SNAP-R Electronic Filing / Tell the Story of Your Application
    • Support Documents / Dual/Third Country Nationals

Sanctions

– with EXERCISES WORKSHOP

  • U.S. Sanctions & Export/Reexport Controls Overview; Specially Designated Nationals
  • Office of Foreign Assets Control: Smart Sanctions and Who These Rules Apply to
  • Embargoed Country Considerations and Destinations: Cuba, Iran, North Korea & Syria
  • Other OFAC Sanctions Programs
  • OFAC Licensing & Approval Policies
  • Important OFAC Sanctions Concepts

Compliance Programs

  • Why Have a Compliance Program?
  • Considerations & Procedural Approaches
    • Internal & External Compliance Resources
    • Where to Get Started
  • USG Compliance Program Recommendations & BIS Core Elements
    • Management Commitment
    • Risk Assessment
    • Formal Written Compliance Program
    • Ongoing Compliance Training & Awareness
    • Compliance Throughout the Export Cycle
    • Recordkeeping Regulatory Requirements
    • Compliance Monitoring & Audits
    • Handling Violations
    • Corrective Action in Response to Export Violations
  • Practical Aspects of Successful Compliance
  • Automate Reexport Compliance
  • Other Considerations: Foreign National Employees/Visitors, Procurement, Information on Servers, Emails, Hand-Carry Exports
  • Keys to Long Term Success

Recent Developments

  • Latest Regulatory Changes
  • Other Recent Developments in the EAR
  • OFAC Sanctions Updates

EAR & OFAC Export Enforcement

  • How U.S. Rules are Enforced Outside the U.S.
    • U.S. Export Enforcement Agencies
  • Statutory & Other Penalties, Possible Outcomes in EAR Penalty Cases
  • Determining EAR Administrative Sanctions
  • Fines and Penalties OFAC, Possible Outcomes in OFAC Penalty Cases
  • Voluntary Self-Disclosures to the U.S. Government
  • Preventing Violations
  • Enforcement Case Studies

 

*Timing and Order of agenda items subject to change

Explore Amsterdam!

Guest Room Reservation

 

VENUE:
DoubleTree by Hilton Amsterdam Centraal Station
Oosterdoksstraat 4
Amsterdam, 1011 DK, Netherlands

*The cost of accommodation is not included in the seminar tuition.

A limited block of guest rooms at the venue hotel is reserved for seminar participants. Group rate ends September 18, 2025.

Rooms are available on a first-come, first-served basis. Book early to ensure availability.

Guest room rate: €295/night Single/Double
To book your room, call the hotel at +31 20 530 0800 and mention group code ECTI group to receive the group rate, or use the guest room booking link.

DoubleTree by Hilton Amsterdam Centraal Station

Health & Safety Notice:
The health and safety of our customers and employees is of critical importance to ECTI. We continue to monitor any public health concerns, and we are committed to meet or exceed applicable guidelines or requirements to ensure the safety of our attendees and speakers.

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Presenters are extremely knowledgeable and engaging. Real world knowledge and practical guidance! I really enjoy the conference (3rd time attending) and always learn something new.

Bryon Relyea

Sr. Trade & Import Compliance Specialist, Avantor

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This was my first experience with ECTI, but it will not be my last. I’ve taken many similar courses over the years, and this was the best. Scott was excellent and his experience in the industry made the course material more accessible and easy to understand. 

William Gregory

UltiSat, Inc.

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ECTI’s training sessions are a “must have” for anyone having a key role in their company’s Export Control Program. ECTI is always improving and updating their program. This is my 3rd time at this seminar.

Joseph Prezioso

Senior Quality Engineer, Consolidated Industries, Inc.

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