Ensuring compliance

IBM devotes significant resources globally to comply with a complex system of export controls Given the breadth of IBM's global operations and dependence on exports, it is vital that IBM be able to conduct operations with minimal delays or other impacts to serve our customers in a competitive IT marketplace. The Export Regulation Office (ERO) is the focal point for a worldwide network of export regulatory professionals that ensure compliance with current export regulations and development of IBM's positions on specific export control issues and best practices.

In the global economy that exists today, export controls need to be based on multilateral agreements to be most effective. For example, unilateral controls based solely in the U.S. will generally fail to achieve their goal and will create competitive disadvantages for U.S. companies with their foreign competitors. IBM supports export controls that advance well defined national policy objectives with a minimal impact on our industry and the economic base. Export controls should be adaptive, administratively efficient and clear. Export policy should recognize when controls are no longer meaningful due to technological or market realities.

The ERO is involved with the following issues:

• Monitor and comment on the U.S. Administration’s export reform initiative
• Encourage a balanced effort to reauthorize the Export Administration Act.
• Ensure that any legislative or regulatory efforts to change licensing and reporting requirements for "dual use" items do not adversely affect ordinary commercial practices and place IBM at a competitive disadvantage.
• Engage with the Departments of Commerce, State and Treasury on a variety of rulemakings.
• Provide corporate oversight over local non-U.S. IBM country export regulation internal control programs.

If you require further assistance, please contact the IBM Export Regulation Office.