Quarterly Inventory Submission Requirements

What is due?

The CAO collects a completed and updated as of date of submission:

  1. Foreign National List Template
  2. Controlled Technology Inventory Template

Please Read: Inventory Guidance

Instructions for CTC POA for Quarterly Export Control Reports

Reporting Deadlines to CAO:

Updated versions of the Foreign National (FN) list and controlled technology inventory (CTI) must be submitted three weeks after the end of the quarter to the Office of the CAO:

Quarter Due Date
First Quarter submissions January
Second Quarter submissions April
Third Quarter Submissions July
Fourth Quarter Submission will be the LO/CO annual Deemed Exports Certification 3rd Week of October

This Certification will certify the deemed export program data for the entire year (see http://deemedexports.noaa.gov/certification_requirements/).
Individual Line Office and Corporate Offices internal deadlines may differ

Controlled Technology Coordinators submit their respective LO/CO submission to Ann Murphy and/or Hugh Schratwieser.

I. Execution Responsibilities:

Responsibilities include, but are not limited to:

  1. Completion of annual certification statements – Submit to CAO Annually
  2. Completion of CT Inventory update- Submit to CAO Quarterly
  3. Completion of FN List updates – Submit to CAO Quarterly
  4. Monitoring if/when DE license may be necessary
  5. Transmission of information to keep LO/CO apprised of regulation/law change
  6. Completion of Access Control Plans for facilities
  7. Other responsibilities- as required by LO/CO to implement internal procedures

The Steering Committee maintains an oversight role to ensure the LO/CO completion of the above responsibilities.

For assistance with NOAA’s deemed exports policy or procedural requirements, please contact your LO/CO Deemed Exports Steering Committee Representative, or the Office of the Chief Administrative Officer and NOAA General Counsel Deemed Exports Team:

For questions related to commodity classification or identifying whether an item is subject to the Export Administration Regulations (EAR), 15 CFR § 730-774, contact Todd Willis or Alex Lopes at the Bureau of Industry and Security (BIS) or use the BIS online request system at http://snap.bis.doc.gov.

II. Specific Responsibilities:

The following three major responsibilities require points of accountability at facilities. LO/CO must to identify points of accountability for these responsibilities.

a. Point of Accountability: Controlled Technology Inventory Assessment per Facility

Required Capability: The point of accountability should be able to classify technology according to the Export Administration Regulations (EAR), 15 CFR § 730-774. The person responsible for maintaining an accurate inventory of controlled technology at a facility must review new purchases as well as NOAA technology. This person is also responsible for completing access control plans for the facility. Several individuals may participate in the assessment process for a facility/division given their technical knowledge.

Helpful Questions (For Point of Accountability)

b. Point of Accountability: FN List Maintenance per Facility

Required Capability: The point of accountability will be able determine a foreign national’s “home” country designation according to EAR. The point of accountability should be able to monitor FN access to the facility. NOAA may sponsor these FNs, or other institutions may sponsor the visa application. If NOAA is the sponsor, information required for completing the FN List may be more readily available than if other institutions sponsor the FN visa. While the OCAO will not be collecting and maintaining a record of your foreign national "visitors," your organization remains accountable for the activities of these "visitors" while they are in your facility. The Departmental Sponsor – NOAA (DSN)/ escort must take all precautions to prevent unauthorized released of technology to foreign national "guests" or "visitors." (DSN and escort requirements are contained in more detail in NAO 207-12.

Helpful Questions (For Point of Accountability)

c. Point of Accountability: Export License Determination

Required Capability: The point of accountability must determine the applicability of deemed export license requirements. This individual needs to understand 15 CFR, 730-744, EAR, exceptions and requirements when checking the CT inventory and FN list to ensure that no license is required. This review occurs when FNs enter the facility and when new pieces of equipment are added to the controlled technology inventory.