CCL Classification    EXPORT RULES    Record Retention    Cautionary Notice
Employee Behavior    Assistance

Statement of Commercial Control List (CCL) Classification

The Vice President of Research and Development has determined, after careful scrutiny of the CCL, that PromptPayPlanner Software is not on the CCL and does not have an ECCN, and is therefore classified EAR99; HOWEVER, EXPORT SALES ARE SUBJECT TO FURTHER SCRUTINY OF OF NAME LISTS (SEE EXPORT RULES).

CCL Classification Overview

(1)  What is it? 

PromptPayPlanner is Not on the Commerce Control List and does NOT have an ECCN and is NOT controlled for "EI" reasons under ECCN 5D002 on the Commerce Control List and is NOT mass market encryption software with symmetric key length exceeding 64-bits.

(2)  Where is it going? 

PromptPayPlanner is exported only to countries permissible under parts 738 and 774 of the EAR Country Chart and Commerce Control List.

(3)  Who will receive it?

PromptPayPlanner is received only by single entities not included in §736.2(b)(4) and parts 744 and 764 of the EAR, provided they are not further subject to export prohibitions.

(4)  What will they do with it?

Recipients of PromptPayPlanner will use it in accordance with General Prohibition Five (End-Use End-User) in §736.2(b)(5) and part 744 of the EAR.  

(5)  What else do they do?

As pertains to PromptPayPlanner and its use, the recipient's conduct does not include contracting, financing, and freight forwarding in support of a proliferation project as described in §744.6 of the EAR.

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Export Rules

Under no circumstances will any employees export PromptPayPlanner to any embargoed country, to any end-user of concern or in support of a prohibited end-use; REGARDLESS OF (CCL) CLASSIFICATION.

All employees must refer to the following government internet document links when determining purchaser/prospect eligibility:

http://www.bis.doc.gov/ComplianceAndEnforcement/ListsToCheck.htm.

http://www.bis.doc.gov/complianceandenforcement/KnowYourCustomerGuidance.htm

• DOWNLOAD AND SEARCH ALL LISTS, EVERY TIME.

• DO NOT UTILIZE OUTDATED LISTS.

• DO NOT ASSUME LISTS ARE ACCURATE.

• ASK QUESTIONS AND GET ANSWERS.

• EXERCISE CAUTION IN NAME SEARCHES. ALIASES MATTER.

• ACCURACY OF ELECTRONICALLY RECEIVED LISTS IS QUESTIONABLE. ALWAYS REQUEST PRINTED LISTS DIRECTLY FROM SOURCE, EVERY TIME. ONCE RECEIVED, REVIEW THOROUGHLY BEFORE PROCEEDING.

POLITELY REFUSE NEGOTIATIONS IF A PROSPECT'S NAME IS LISTED, OR  IS ASSOCIATED WITH ANY ENTITY LISTED.

At shipping time employees are to indicate "NLR" as authorization for export on the Shipper’s Export Declaration. By signing the SED (or designating the freight forwarder to do so), the employee is certifying that your item is eligible for NLR.

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Cautionary Notice to Prompt, Incorporated Employees

Export guidelines and requirements contained herein were obtained from the electronic public domain (government internet sites). For our purposes, in the context of export controls, information in the electronic public domain will NOT be deemed accurate and reliable on face value alone, and must be compared with the print-published counterpart whenever possible. 

Employees are advised to contact our Vice President of Research and Development, verbally, with any questions.

Prompt, incorporated Employee behavior

all employees (temporary and permanent) of prompt, incorporated are required to review this, the associated documentation, and bis published lists semi-annually and always prior to any sales negotiations FOR EXPORT SALES.

Employees who disregard these controls will be in violation of the employment contract and will be subject to immediate dismissal.

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Record Retention

All employees shipping PromptPayPlanner retain records relating to NLR determination and the export transaction for five years.

Getting Assistance

Any employee requiring additional assistance and/or clarifications is directed to the following government internet document link:

http://www.access.gpo.gov/bis/index.html

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