Todd E. Willis
Director
Munitions Control Division
Bureau of Industry and Security
U.S. Department of Commerce


In August 2009, the President directed a broad-based interagency
review of the U.S. export control system.
The Administration determined that fundamental reform of the
current system is necessary to enhance our national security by
◦ (i) focusing resources on the threats that matter most;
◦ (ii) increasing interoperability with our Allies;
◦ (iii) strengthening the U.S. defense industrial base by reducing
incentives for foreign manufacturers to design out and avoid
using U.S. parts and components.

In April 2010, Secretary of Defense Robert Gates identified four
singulars for reform:
(1) Single IT system;
(2) Single control list;
(3) Single law enforcement coordination agency;
(4) Single licensing agency.

The Administration is recalibrating the controls and licensing
requirements on items that pose a low risk to national security
◦ This is not a decontrol but a common sense, good government
prioritization of our controls.


The reform initiative will enhance, not ease, the prohibitions on
destinations like Cuba, Iran, North Korea, Sudan and Syria, and will
enhance, not ease, U.S. policy of not supporting China’s military
modernization program.
The President’s entire national security team supports a
comprehensive overhaul of the system to meet the current and
anticipated U.S. national security and foreign policy objectives of the
21st century.
The Administration has deployed a three-phase implementation plan.
Phases I and II: Progress to date:
 Developed and published the methodology for rebuilding the control lists,
and will be implementing these regulatory changes on a rolling schedule.
◦ 20 categories, published 9 (18 proposed rules, 1 each for State and
Commerce per category)
◦ 3 more (6 rules) in the OMB clearance process.
◦ That leaves 4 more (8 rules) to move to OMB for publication.
◦ Begin AECA requirement, 38(f) Congressional notification process summer
2012.
◦ Start publishing final rules fall 2012.
Note: Categories: XV, XVI, XVII, XVIII; separate reviews
Phases I and II: Progress to date:
◦ Executive Order 13558 created the Export Enforcement Coordination Center (E2C2).
◦ The Administration and Congress partnered to pass legislation, the Comprehensive
Iran Sanctions, Accountability, and Divestment Act (CISADA), to increase the disparate
criminal export enforcement penalties to a standardized maximum. It also provided
the Department of Commerce with permanent law enforcement authority that had
been in lapse.
◦ An electronic consolidated list of parties was developed to assist small- and mediumsized companies screen transactions to ensure items are exported in compliance with
licensing and other export control requirements.
◦ Four departments – Commerce, Defense, Energy, and State – are already migrating to
a single secure licensing IT system administered by Defense; other departments will
follow.
Phase III will require legislation to implement a government reorganization that would
consolidate the current system.
xY6zz
CCL Category
0-9
Last two characters
(i.e. numbers) will
generally track
the WAML
Product
Group
A-E
The “600 series”
derives its name
from the 3rd
character (i.e.,
number) of the
ECCN.
“600 series” items will generally be controlled for the following reasons
for control:
 National Security column 1 (NS1); Regional Stability column 1 (RS1);
Anti-terrorism column 1 (AT1).
 License required for export or reexport to all countries except
Canada (excluding certain items controlled for MT, CB1 & FC
reasons)
 Regime controlled items retain regime control.
 STA (ultimate government end-use), GOV, RPL
Specific parts, components, accessories and attachments identified in
.y paragraphs.
 Anti-terrorism column 1 (AT1)

Restrictions on certain military end-uses in the PRC in §744.21, and
other end-use and end-user controls as applicable.
USML F-16
IllustrativeF-16
List
Only
•
•
•
•
•
•
•
•
•
•
•
•
•
Specific USML Items
Assembled engines
Weapons pylons
Mission systems
Bomb racks
Missile launchers
Fire control computer
Radar
Radar warning receiver
Radar jammer
Laser/Missile warning system
Countermeasures dispensing system
Aerial refueling receptacle
Helmet mounted displays/Sights
Other Aircraft USML Items
• Aircraft wing folding systems and parts & components
• Tail hooks and arresting gear and parts and
components
• Missile rails, weapon pylons, pylon-to launcher
adapters, UAV launching systems, and external stores
support systems and parts and components
• Damage/failure-adaptive flight control systems
• Threat-adaptive autonomous flight control systems
• Air-to-air refueling systems and hover-in-flight
refueling (HIFR) systems and parts and components
• UAV flight control systems and vehicle management
systems with swarming capability
Reference Federal Register / Volume 76, No. 215 / Monday, November 7, 2011 / Proposed rules, page 68697
ECCN 9A610 - F-16
Illustrative List Only
Wings, Rudder, Fin, Panels
Fuselage – Forward, Center, Aft
Cockpit structure
Forward equipment bay
Horizontal stabilizer
Conformal fuel tank
Cartridge Actuated Device, Propellant
Actuated Device (CAD/PAD)
• Control surfaces, activation & control systems
•
•
•
•
•
•
•
Reference Federal Register / Volume 76, No. 215 /
Internal & Exterior fuel tanks
Engine inlets and ducting
Wing box
Flaperon
Static structural members
Exterior skins, Fairings, Radomes, Access doors
Leading edge flap
• Landing gear
• Technology associated with above items
•
•
•
•
•
•
Monday, November 7, 2011 / Proposed rules, page 68689
THANK YOU
Todd Willis
(202) 482-1477
MCD Contact
Todd.Willis@bis.doc.gov
Dale Alford
(202) 482-3413
Information
Dale.Alford@bis.doc.gov
John Cuyler III
(202) 482-3475
John.Cuyler@bis.doc.gov
Thomas Defee
(202) 482-3365
Thomas.Defee@bis.doc.gov
Rey Garcia
(202) 482-3462
Reynaldo.Garcia@bis.doc.gov
Karen DiBenedetto
(202) 482-4524
Karen.DiBenedetto.bis.doc.gov