VP/Director Export Compliance & Licensing [Your Company] Raymond J. Castagnaro, CPCM 29 April 2009

[Your Company]

Introduction Raymond J. Castagnaro, CPCM Over 20 years experience Top Graduate, International Import-Export Institute’s (IIEI) course “Orientation for Empowered Officials” (2005) Achieved the only perfect score in the history of the course Empowered Official per ITAR 120.25 Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

Raymond J. Castagnaro, CPCM

Over 20 years experience

Top Graduate, International Import-Export Institute’s (IIEI) course “Orientation for Empowered Officials” (2005)

Achieved the only perfect score in the history of the course

Empowered Official per ITAR 120.25

§ 120.25 Empowered Official (a) Empowered Official means a U.S. person who: (1) Is directly employed by the applicant or a subsidiary in a position having authority for policy or management within the applicant organization; and (2) Is legally empowered in writing by the applicant to sign license applications or other requests for approval on behalf of the applicant; and (3) Understands the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability and administrative penalties for violating the Arms Export Control Act and the International Traffic in Arms Regulations ; and (4) Has the independent authority to: (i) Enquire [sic] into any aspect of a proposed export or temporary import by the applicant, and (ii) Verify the legality of the transaction and the accuracy of the information to be submitted; and (iii) Refuse to sign any license application or other request for approval without prejudice or other adverse recourse . (b) [Reserved] Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

(a) Empowered Official means a U.S. person who:

(1) Is directly employed by the applicant or a subsidiary in a position having authority for policy or management within the applicant organization; and

(2) Is legally empowered in writing by the applicant to sign license applications or other requests for approval on behalf of the applicant; and

(3) Understands the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability and administrative penalties for violating the Arms Export Control Act and the International Traffic in Arms Regulations ; and

(4) Has the independent authority to:

(i) Enquire [sic] into any aspect of a proposed export or temporary import by the applicant, and

(ii) Verify the legality of the transaction and the accuracy of the information to be submitted; and

(iii) Refuse to sign any license application or other request for approval without prejudice or other adverse recourse .

(b) [Reserved]

Experience as an E.O. DRS Technologies, Inc., Reconnaissance, Surveillance, & Target Acquisition (RSTA) Business Segment - I know Defense products and their ITAR implications Bell Helicopter Textron - Strong background in aircraft systems, weapons platforms, etc. Coltec Industries, Menasco Aerospace - EO for five divisions of the company Honeywell, Inc. - Satellite Systems - Electric actuators Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

DRS Technologies, Inc., Reconnaissance, Surveillance, & Target Acquisition (RSTA) Business Segment - I know Defense products and their ITAR implications

Bell Helicopter Textron - Strong background in aircraft systems, weapons platforms, etc.

Coltec Industries, Menasco Aerospace - EO for five divisions of the company

Honeywell, Inc. - Satellite Systems - Electric actuators

Professional Contacts Attend Society for International Affairs (SIA) conferences twice annually Industry peers are highly-placed EOs for Airbus, QioptiQ, Lockheed-Martin, Boeing, Bell Helicopter, EFW, others Well-respected by Licensing Officers and Enforcement officials at DoS (DDTC, DTCC) and DoD (DTSA, USAF, USA) Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

Attend Society for International Affairs (SIA) conferences twice annually

Industry peers are highly-placed EOs for Airbus, QioptiQ, Lockheed-Martin, Boeing, Bell Helicopter, EFW, others

Well-respected by Licensing Officers and Enforcement officials at DoS (DDTC, DTCC) and DoD (DTSA, USAF, USA)

Member of the Team Some EOs see themselves as gatekeepers only Fosters the image of “Dr. No” or an obstacle to be overcome, especially by BD, Engineering, Supply Chain I have a background in Business Development and Marketing, Program Management, Supply Chain, and Contracts (CPCM) - I speak the language My mission is to ensure that my company makes its profit and revenue goals and KEEPS what it earns (e.g. fines and penalties subtract from the bottom line) Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

Some EOs see themselves as gatekeepers only

Fosters the image of “Dr. No” or an obstacle to be overcome, especially by BD, Engineering, Supply Chain

I have a background in Business Development and Marketing, Program Management, Supply Chain, and Contracts (CPCM) - I speak the language

My mission is to ensure that my company makes its profit and revenue goals and KEEPS what it earns (e.g. fines and penalties subtract from the bottom line)

How do we do that? VP Export Compliance & Licensing has a seat at the President’s table Train Core Employees and Key Personnel - TRAIN TRAIN TRAIN! Include Compliance and Licensing in the earliest stages of Strategic and Tactical Planning Streamline the compliance & licensing function by simplifying and balancing the process across the enterprise Obtaining “Permission” early in the strategic planning, business development, and procurement cycles is far more cost-effective than attempting to obtain "forgiveness" for noncompliance later Permission = licenses, agreements, commodity jurisdiction requests, advisory opinions, general correspondence clarifications, and proper use of exemptions Forgiveness = Disclosures & Corrective Actions Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

VP Export Compliance & Licensing has a seat at the President’s table

Train Core Employees and Key Personnel - TRAIN TRAIN TRAIN!

Include Compliance and Licensing in the earliest stages of Strategic and Tactical Planning

Streamline the compliance & licensing function by simplifying and balancing the process across the enterprise

Obtaining “Permission” early in the strategic planning, business development, and procurement cycles is far more cost-effective than attempting to obtain "forgiveness" for noncompliance later

Permission = licenses, agreements, commodity jurisdiction requests, advisory opinions, general correspondence clarifications, and proper use of exemptions

Forgiveness = Disclosures & Corrective Actions

What if we need “Forgiveness”? One of the value added benefits of a continuously improving export compliance program, driven by a senior member of the CEO's executive staff , is his/her relationship with the USG Your company has already shown a promising approach to trade compliance by seeking top talent from the industry and positioning that talent where it can do the most good: The Defense Trade Controls (DDTC) and Trade Controls Compliance (DTCC) organizations of the State Department consistently direct corrective action that includes doing exactly what you are doing now : elevating export compliance from an adjunct to a key executive role Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

One of the value added benefits of a continuously improving export compliance program, driven by a senior member of the CEO's executive staff , is his/her relationship with the USG

Your company has already shown a promising approach to trade compliance by seeking top talent from the industry and positioning that talent where it can do the most good: The Defense Trade Controls (DDTC) and Trade Controls Compliance (DTCC) organizations of the State Department consistently direct corrective action that includes doing exactly what you are doing now : elevating export compliance from an adjunct to a key executive role

“ Forgiveness” Continued I have a reputation with the DTCC Enforcement officers, including its Chief, for providing them with what they need to “forgive” (“Same guy - different company”) All of my disclosures have remained Voluntary ($ zero penalties/fines on my watch) Have never been forced into a Directed Disclosure or a Consent Agreement Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

I have a reputation with the DTCC Enforcement officers, including its Chief, for providing them with what they need to “forgive” (“Same guy - different company”)

All of my disclosures have remained Voluntary ($ zero penalties/fines on my watch)

Have never been forced into a Directed Disclosure or a Consent Agreement

Compliance, Registration, Audits Have been through DDTC Audits by Deb Carroll (now Division Chief) and US Customs Known and well-respected by NVESD (Army) licensing officers Have close professional relationships with partners at Poliner & Luks, Pisani & Roll, and auditors/outside counsels at DLA Piper, McKenna, Long, & Aldridge Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

Have been through DDTC Audits by Deb Carroll (now Division Chief) and US Customs

Known and well-respected by NVESD (Army) licensing officers

Have close professional relationships with partners at Poliner & Luks, Pisani & Roll, and auditors/outside counsels at DLA Piper, McKenna, Long, & Aldridge

The Roadmap - Year 1 Register with Corporation and DDTC as the company’s Empowered Official Build trust and mutual respect with all executives in the company Do the same with Export Personnel and executives of all supported business units - any already planned gatherings make this easier and cost-effective - The goal here is to Build/Improve the Team Review and begin revision of ANY existing Trade Compliance processes, procedures, manuals, etc. If not already automated, (depending on budget,) implement customized/packaged software (i.e. OCR EASE) for Compliance requests, licenses, agreements, exemptions tracking Create or improve the company-wide product matrix: Product, ITAR Category or EAR ECCN#, other pertinent information The Goal is a “One Company” approach to Compliance (We use and improve the good, replace the not-so-good tools) Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

Register with Corporation and DDTC as the company’s Empowered Official

Build trust and mutual respect with all executives in the company

Do the same with Export Personnel and executives of all supported business units - any already planned gatherings make this easier and cost-effective - The goal here is to Build/Improve the Team

Review and begin revision of ANY existing Trade Compliance processes, procedures, manuals, etc. If not already automated, (depending on budget,) implement customized/packaged software (i.e. OCR EASE) for Compliance requests, licenses, agreements, exemptions tracking

Create or improve the company-wide product matrix: Product, ITAR Category or EAR ECCN#, other pertinent information

The Goal is a “One Company” approach to Compliance (We use and improve the good, replace the not-so-good tools)

Year 2 and beyond All company Export Personnel to attend SIA conferences at least once annually (Beginner and Advanced course, as appropriate) I will attend both courses with them Quarterly Compliance Team gatherings with one annual company-wide Compliance seminar for all team members (presentations, guest speakers, workshops, etc.) Make presentations to DDTC and DTSA for new products or for any legacy products that might be the subject of Commodity Jurisdiction requests - this outreach gains the trust of USG licensing officials. Maintain Year 1 activities Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

All company Export Personnel to attend SIA conferences at least once annually (Beginner and Advanced course, as appropriate)

I will attend both courses with them

Quarterly Compliance Team gatherings with one annual company-wide Compliance seminar for all team members (presentations, guest speakers, workshops, etc.)

Make presentations to DDTC and DTSA for new products or for any legacy products that might be the subject of Commodity Jurisdiction requests - this outreach gains the trust of USG licensing officials.

Maintain Year 1 activities

Thank you again ... for your time and attention Are there any questions not already addressed? Please contact through Linked In. Monday, April 20, 2009 Copyright (c) Raymond J. Castagnaro 2009 All rights reserved

... for your time and attention

Are there any questions not already addressed? Please contact through Linked In.