Summit Software

It is the policy of Summit Software Company to comply fully with the export laws and regulations of the United States government. As part of this policy, Summit is providing this site as a service to our partners and customers. Please note that this site is intended as a source of information only and is not to be considered a source of legal guidance or advice.

Before considering the export of a Summit product, customers should review the License Agreement that came with the product to verify if the terms of the agreement allow the product to be moved out of a given country or region.

Laws and Regulations
Great care must be taken when exporting, re-exporting, or transferring Summit products or technology.

Summit products and technology are considered “Country of Origin: U.S.A.” Therefore, the export or re-export of these products, or transfer of these technologies, is subject to the export laws and regulations of the United States. The primary agencies that administer and enforce these laws and regulations are the Bureau of Industry and Security and the Office of Foreign Assets Control.

The scope of the U.S. export laws and regulations primarily includes

• The export of U.S. products or technology from the United States
• The movement of U.S. products or technology outside of the United States
• The movement of non-U.S. products or technology that have U.S. content

Licensing
An export license is required before proceeding with a transaction that involves embargoed or restricted countries, denied parties, certain parties involved with weapons of mass destruction, or parties involved in denied end uses.

Compliance Procedures
There are a number of issues to consider when exporting, but the basic export compliance procedure for a transaction involving Summit products or technology is as follows:

1. Obtain the ECCN of the product or technology and determine which export restrictions apply.
2. Screen all parties involved against the latest denial lists. 
3. Determine if any of the parties are involved in denied activities relating to the design, development, production, stockpiling, or use of weapons of mass destruction.
4. Determine if any of the parties are involved in denied activities such as terrorism or illegal narcotics trafficking.

Export Control Classification Numbers (ECCN)
Please contact the Summit Export Controls Department to obtain the correct ECCN for the Summit product you intend to export.

Denial Lists
To obtain the latest denial list information, such as the latest updates of the Denied Persons List or the Entity List, please contact the Bureau of Industry and Security. For information about the latest update of the Specially Designated Nationals List, please contact the Office of Foreign Assets Control. You should contact both agencies for information on the embargoed countries.

Weapons of Mass Destruction and Other Denied End Uses 
When exporting, re-exporting, or transferring Summit products or technology, the end user or other parties included in the transaction must not be involved in the design, development, production, stockpiling, or use of nuclear weapons; missiles; chemical or biological weapons, agents, or precursors. There are some countries that are exempted from some of these restrictions but you will need to contact the Bureau of Industry and Security to determine if the exemptions will apply for a given end user or transaction. 

Do not proceed with a transaction if you have reason to suspect that any party is either on a denial list, involved in weapons of mass destruction work or involved in denied activities such as illegal narcotics trafficking or terrorism.

Export Counseling
It is beyond the scope of this site to offer counseling or advice on export compliance issues. Please contact the relevant government agencies for counseling and guidance on export licensing and other issues as well as access to the latest information on embargoes and denial lists. Employing an export compliance consultant should also be considered.