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IRAC Method of Legal Reasoning Case Study

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Assignment 5 Submission Leandro Couto Correia
QezTek Inc. is a U.S. company that has developed a new high-tech ultrasonic object detection
sensor. This new, highly sensitive sensor can be used in civilian vehicles to alert drivers when
other cars or even small objects (like squirrels) are in a driver’s blind spot. The new sensor also
has the potential to be used in military vehicles to better detect surrounding objects and threats.
QezTek would like to export its sensors to a vehicle manufacturer, Royota Inc. in Japan. This
export may be subject to the Export Control Regulations, ITAR, and OFAC Regulations.
1) Make a list of at least 7 questions that QezTek will need to determine the answers to
before exporting the sensors to Royota factories in Japan.
2) For applicable questions, indicate any U.S. government issued list or resource that
QezTek should reference in order to answer the question.
Example: Do the Export Administration Regulations prohibit exports to Royota Inc. specifically?
- QezTek should reference the U.S. Dept. of Commerce, Bureau of Industry & Security “Entities
or Denied Persons List” to determine if Royota Inc. is included on the list.
Answer:
1) Which regulation(s), among Export Control Regulations (ECR), ITAR and OFAC, these
sensors are subject to? QezTek should reference to U.S. Dept. of Commerce Bureau of
Industry and Security (BIS), U.S. State Department - Bureau of Arms Control, Verification
and Compliance (AVC) and U.S. Department of the Treasury Office of Foreign Assets
Control (OFAC), respectively.
2) If the sensors are subject to ECR, in which of the 10 categories of the Commerce Control
List do they fall? QezTek should reference to U.S. Dept. of Commerce Bureau of
Industry and Security (BIS)
3) If the sensors are subject to ECR, what would be their Export Control Commerce Number
(ECCN)? QezTek should reference to U.S. Dept. of Commerce Bureau of Industry and
Security (BIS)
4) If the sensors are subject to ECR, what would be the process to apply for the adequate
licenses? QezTek should reference to U.S. Dept. of Commerce Bureau of Industry and
Security (BIS)
5) If the sensors are subject to ECR, is Japan under any of the International Trade
Administration (ITA) projects? QezTek should reference to U.S. Dept. of Commerce,
Bureau of International Trade Administration
6) If the sensors are subject to ECR, are they being exported for restricted end uses? ?
QezTek should reference to U.S. Dept. of Commerce Bureau of Industry and Security
(BIS)

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Assignment 5 Submission – Leandro Couto Correia QezTek Inc. is a U.S. company that has developed a new high-tech ultrasonic object detection sensor. This new, highly sensitive sensor can be used in civilian vehicles to alert drivers when other cars or even small objects (like squirrels) are in a driver’s blind spot. The new sensor also has the potential to be used in military vehicles to better detect surrounding objects and threats. QezTek would like to export its sensors to a vehicle manufacturer, Royota Inc. in Japan. This export may be subject to the Export Control Regulations, ITAR, ...
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