Export Compliance

⚠️ Important Export Control Notice

LMCU Technologies Inc. products, technology, software, and technical data are subject to U.S. export control laws and regulations, including but not limited to:

• International Traffic in Arms Regulations (ITAR) - 22 CFR 120-130
• Export Administration Regulations (EAR) - 15 CFR 730-774
• Office of Foreign Assets Control (OFAC) Sanctions

Unauthorized export, re-export, or transfer of LMCU technology may result in severe civil and criminal penalties.

1. Export Control Overview

LMCU Technologies Inc. ("LMCU") is committed to full compliance with all applicable U.S. export control laws and regulations. Our Lake Michigan Control Unit systems incorporate advanced aerospace navigation and motion control technology that may be subject to export restrictions.

1.1 Why Export Controls Apply

LMCU products and services fall under export control jurisdiction due to:

• Defense and military applications (ITAR-controlled)
• Dual-use technology with potential military applications (EAR-controlled)
• Advanced navigation and guidance systems
• Artificial intelligence and machine learning algorithms
• Spacecraft control and orbital positioning technology
• Technical data and software related to controlled items

1.2 Applicable Regulations

International Traffic in Arms Regulations (ITAR): Certain LMCU products are designated as defense articles under USML Categories VIII (Aircraft), XI (Military Electronics), XV (Spacecraft), and XXI (Miscellaneous).

Export Administration Regulations (EAR): Commercial LMCU technology may be classified under ECCN 7A994 (navigation equipment), 7D994 (software), 9A991 (aerospace), or other applicable categories.

2. Restricted Parties and Countries

2.1 Prohibited Destinations

LMCU technology may not be exported or re-exported to embargoed or sanctioned countries, including but not limited to:

• Cuba
• Iran
• North Korea (DPRK)
• Syria
• Crimea, Donetsk, and Luhansk regions of Ukraine
• Other countries subject to comprehensive U.S. sanctions

2.2 Denied Parties Screening

LMCU screens all customers, partners, and users against U.S. Government restricted parties lists:

• Denied Persons List (DPL)
• Entity List (EL)
• Unverified List (UVL)
• Specially Designated Nationals (SDN) List
• Military End User (MEU) List
• Debarred List (ITAR)

Transactions with parties appearing on these lists are prohibited without specific authorization from the U.S. Government.

3. ITAR Compliance

3.1 ITAR Registration

LMCU Technologies Inc. is registered with the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) as a manufacturer and exporter of defense articles.

Registration Code: [REDACTED]
Registering Agency: Directorate of Defense Trade Controls (DDTC)

3.2 U.S. Person Requirements

Access to ITAR-controlled LMCU technology is restricted to "U.S. Persons" as defined in 22 CFR 120.15:

• U.S. citizens
• Lawful permanent residents (Green Card holders)
• Protected individuals (refugees and asylees)
• U.S. corporations, partnerships, and organizations not under foreign ownership, control, or influence

Foreign nationals (including visa holders) may only access ITAR-controlled information with a valid Technical Assistance Agreement (TAA) or export license.

3.3 Export Licenses

International transfers of ITAR-controlled LMCU products require prior authorization:

• DSP-5: License for permanent export of defense articles
• DSP-61: License for temporary import (for foreign customers)
• DSP-73: License for temporary export
• TAA: Technical Assistance Agreement for defense services
• MLA: Manufacturing License Agreement for foreign production

4. EAR Compliance

4.1 Commerce Control List (CCL)

Certain LMCU commercial products are classified under the Export Administration Regulations:

• ECCN 7A994: Other navigation direction finding equipment
• ECCN 7D994: Software for navigation systems
• ECCN 9A991: Aerospace structures and components
• ECCN 3D001: Software for development of electronic components

4.2 Export Licensing

Depending on destination and end-use, EAR-controlled items may be exported under:

• No License Required (NLR): For eligible countries and end-uses
• License Exception: Such as License Exception ENC, TSR, or GOV
• BIS Export License: Required for sensitive countries or end-uses

4.3 Deemed Exports

Release of controlled technology to foreign nationals within the United States is considered a "deemed export" and requires authorization if the technology would require a license to the person's country of nationality.

5. End-Use and End-User Restrictions

5.1 Prohibited End-Uses

LMCU technology may not be used for:

• Development, production, or use of weapons of mass destruction (nuclear, chemical, biological)
• Development or production of missiles or unmanned aerial systems for military use
• Military applications by countries subject to U.S. arms embargo
• Terrorism or support of terrorist organizations
• Human rights abuses or destabilizing military activities

5.2 End-User Statements

LMCU may require customers to provide written certifications regarding:

• End-use of technology (commercial vs. military applications)
• Ultimate consignee and end-user identity
• Country of ultimate destination
• Commitment not to re-export without authorization

6. Customer Responsibilities

When purchasing, accessing, or using LMCU technology, customers agree to:

6.1 Compliance Obligations

• Comply with all applicable U.S. export control laws and regulations
• Obtain required licenses before re-exporting LMCU technology
• Maintain records of exports and re-exports for 5 years
• Implement internal export compliance programs
• Train employees on export control requirements
• Report violations or suspicious activities to LMCU and authorities

6.2 Information Requirements

Customers must provide accurate information regarding:

• Nationality and citizenship of users accessing LMCU technology
• Location where technology will be used or stored
• Intended end-use and application
• Corporate ownership structure and foreign affiliations

6.3 Prohibited Actions

• Transferring LMCU technology to unauthorized persons or countries
• Providing access to foreign nationals without proper authorization
• Engaging in transactions with denied parties
• Falsifying information on export documentation
• Participating in boycotts not sanctioned by the U.S. Government

7. LMCU Internal Controls

7.1 Export Compliance Program

LMCU maintains a comprehensive export compliance program including:

• Dedicated Export Compliance Officer (ECO)
• Written export compliance policies and procedures
• Regular employee training and certification
• Automated denied parties screening system
• Technology classification reviews
• Export license management and tracking
• Record retention systems (minimum 5 years)
• Internal audits and compliance assessments

7.2 Access Controls

LMCU implements physical and technical controls to prevent unauthorized access:

• LMCU login portal with multi-factor authentication
• Role-based access controls for controlled technology
• Visitor management and foreign national tracking
• Secure facilities with access restrictions
• Data encryption and secure file transfer protocols
• Network segmentation for ITAR-controlled systems

8. Violations and Penalties

8.1 Civil Penalties

Violations of U.S. export control laws may result in:

• ITAR violations: Up to $1,000,000 per violation
• EAR violations: Up to $300,000 per violation or twice the value of the transaction
• Denial of export privileges
• Debarment from government contracting

8.2 Criminal Penalties

Willful violations may result in criminal prosecution:

• Imprisonment up to 20 years per violation
• Fines up to $1,000,000 for individuals
• Fines up to $5,000,000 for organizations
• Forfeiture of assets involved in violations

8.3 Voluntary Self-Disclosure

LMCU encourages employees and customers to report potential violations. Voluntary self-disclosure may result in reduced penalties.

9. International Customers

9.1 Pre-Approval Requirements

Before providing LMCU technology to international customers, we require:

• Completed export compliance questionnaire
• End-user and end-use statements
• Corporate ownership documentation
• Government authorization (if applicable)
• Signed Technology Transfer Agreement (for ITAR items)

9.2 Foreign Government Customers

Sales to foreign governments or military organizations require:

• Foreign Military Sales (FMS) program approval, or
• Direct Commercial Sale (DCS) with State Department license
• Congressional notification (for sales exceeding thresholds)

10. Ongoing Compliance

10.1 Changes in Regulations

Export control regulations are subject to frequent changes. LMCU continuously monitors regulatory updates and adjusts compliance procedures accordingly.

10.2 Customer Notifications

LMCU will notify customers of:

• Changes in export classifications of products
• New license requirements affecting existing products
• Updates to export compliance policies

11. Contact Export Compliance

For export control questions or to report potential violations:

LMCU is committed to full compliance with U.S. export control laws. This policy applies to all LMCU employees, contractors, customers, and partners. Violations will not be tolerated and may result in termination of business relationships and referral to law enforcement.