How Can I Sign Connecticut Electrical Services Contract

How can i document type sign electrical services contract connecticut

[Music] welcome and thank you for standing by this time all participants will be on a listen-only mode until the question and answer session of today's conference at that time if you'd like to ask a question over the phone lines please press star 1 on your phone and record your name at the prompt this call is being recorded give any objections please disconnect at this time I would now like to turn the call over to your host Melissa Grosso thank you may begin great thank you very much and welcome everyone to our third of 17 webinars for those of you who joined us for the BIS and HR webinars you did hear mention the importance of having an economic sanctions paying attention to economic u.s. economic sanctions as part of a robust export compliance program so I'm really pleased that we have we have two individuals from the Office of Foreign Assets Control under the Department of Treasury with us today as a reminder you can ask questions through the written queue which is on the lower right hand side of your screen we will have an audio QA as we have the previous webinars at the end of the presentation one final housekeeping note for those of you who are on the ITAR webinar last Thursday we are still working on some technical issues of getting the net replay out but we hope to have that resolved within 24 hours or so and with that I'd like to again thank our speakers and welcome that Kaufman and Vanessa are in court from the Department of Treasury's Office of Foreign Assets controls Zach will turn it over to you thank you very much and hi everyone thank you for attending this OPEC 101 webinar today we really appreciate your time my name is Zach and my co-facilitator is Vanessa that's previously stated what we'll be covering today is on slide to the agenda slide if you do have questions we will have time at the end for a Q&A section but to get started the first section we will cover is OPEC basics on slide 4 so Colfax mission is to administer and enforce economic and trade sanctions based on a u.s. foreign policy and national security goals again specially selected targets these include but are not limited to foreign countries and/or foreign regimes terrorists international narcotic traffickers and war criminals and their support structures and those engaged in activities related to the proliferation of weapons of mass destruction sanctions are wrong tool along with diplomatic and military options that the u.s. uses to advance foreign policy both acts mission is sweeping and requires wide-ranging actions to meet its goals oftentimes this includes identifying foreign adversaries developing sanctions programs against those adversaries assisting US persons and complying with sanctions prohibitions and penalizing US persons for violating these prohibitions in many certain census cofac works and cooperation cooperation with US law enforcement this coordination brings the full weight and influence of the federal government to advance US foreign policy colfax authority to impose impose controls on transactions and freeze assets under US jurisdiction is based on constitutional wartime statutory authorities and presidential national emergency powers and other authorities granted by specific legislation these actions are meant to preserve and protect the United States national security foreign policy and economy many of OPEC sanctions are based on United Nations and other international agreements are multilateral in scope and involved close cooperation with other governments to acts which our most familiar are most related to OPEC are the IEEPA and Tweed acts international emergency economic Powers Act and the training with the MA alright moving on the slide spot jurisdiction sanctions programs prohibit us persons from most dealings with foreign adversaries in their support structures u.s. persons are defined as and it is laid out pretty clearly on the slide but it is worth repeating that American citizens and permanent residents aliens wherever they are located any individual regardless of students citizenship who is physically located in the United States and corporations organized under US law including foreign branches of US companies and in case in the case of Cuba and North Korea foreign subsidiaries of US companies any corporation or company physically as well as any corporation or company located in the United States so it's five six is specifically about th track at the inlet one of several US government watch lists especially designated national or SPN list is a compliance tool published by OPEC to assist US persons and identifying foreign adversaries with whom it is illegal to do business to help us persons comply with sanctions effect especially designates foreign adversaries individuals and entities by collecting evidence to show that their activities or relationships meet the criteria outlined in the executive order or statute imposing the sanctions these individuals and entities are placed on the list especially designated Nationals and block persons or SD endless however this list is not exhaustive collectively all the designated parties included on this list are called especially designated Nationals or SDNS the integrated list of the excuse me the list of these names called the excellent Afghan list and is accessible through the effect website u.s. persons are responsible for not dealing with sanctions targets regardless of whether or not these persons are on the Afghan list for example there are broad prohibitions on dealing with governments of sanction countries nevertheless the SDN list will not contain the names of all the government bodies of those countries and we will have their slides at the end that do cover locations of these on the Treasury website slide 7 we'll go over general licenses and exemptions in order to engage in a transaction that would otherwise be prohibited by affects a person or persons must first obtain a license to engage in that activity there are two kinds of licenses the general license is revision contained in effect regulations which authorizes a particular type of transaction a person does not need to apply for a general license because the regulation itself authorizes the transaction a person engaging in a transaction pursuant to a general license must make sure that all conditions of the provision are strictly observed on the other hand a specific license is a written document issue biomech to a particular person or entity authorizing a particular transaction regulations may contain statements of effect specific licensing policy with respect to particular transactions so Civic licenses are only issued in response to a written license application meaning you would have to go into our website and apply for it it's not similar to the general license and any buddy it's open to the public to use programs also have exemptions and statements of licensing policy an exemption is exactly that the category of transaction exempt from the prohibition for example common exemptions are informational materials and travel with the exception of Cuba a statement of licensing policy is it issued to clarify where OPEC stands on a topic or to clarify when it will consider reviewing specific licenses alright now we will transition to a package from OPEC basics to sanctions programs slide 9 so OPEC administers and enforces 26 sanctions programs and maintains over 5,500 entries on the SPM list well fax objective is to identify expose isolate impede and incapacitate foreign adversaries and their support structures in fact accomplish this is specific accomplishes these objectives in five ways first by the nine foreign adversaries access to the US financial system and the ability to trade US companies second by denying foreign adversaries the use of their property limit possession or control of US persons third by working with the US persons to help them meet their obligation to not have dealings with prohibited parties fourth through coordination with other US agencies to bring to bear the full weight and influence of the federal government regulatory diplomatic defense intelligence and enforcement against these foreign adversaries and their support structures and fifth by working with other nations to implement similar strategies through outreach and compliance activities like this OPEC provides assistance to US persons in complying with the sanctions prohibitions oftentimes this includes direct contact with financial institutions and Porter's exporters and individuals additional assistance right into our hotline website publications presentations to government and industry groups again we will be going over ways to contact us and website locations at the end of the presentation the first of effects primary tools is blocking the property and property interest of sanctions targets blocking by definition is an action that prohibits access to an account or property with respect to payments transfers exportations withdrawals or any other dealings except those pursuant to a license for other authorization from effect property and property interests are defined very broadly to include but not limited to money checks accounts securities mortgages Goods ships patents insurance policies services of any nature contract of any nature and any other property real personal mixed tangible or intangible or interest therein direct or indirect whether present feature or contingent the second tool involves restrictions on dealing with sanctions targets providing limited or comprehensive prohibitions against the import export of goods for services to or from the target okay slide 10 will be going over lists based programs there is a breakdown and the programs in the administer one is list based the second is comprehensive list based programs are numerous and vary in size and scope in other words lids based programs are typically restricting or prohibiting us and/or import of services finance goods and services involving prohibited parties but there are no broad robe again prohibitions against a country that is categorized as a list or targeted so common one is the Balkans program for the African programs the programs against Venezuela those are list based programs you would need to be cognitive and an SDN is not involved in a transaction for example excuse me in the context of exporting or importing US persons are not allowed straight with any individual or entity in a list country as long as the trees not directly or indirectly benefiting a designated party excuse me let me restate that u.s. persons are allowed to trade with any individual or entity in a list based country as long as the tree is not directly or indirectly benefiting a designated party generally licenses are normally associated with Capri country comprehensive programs since they are allowing for practices that would normally be restricted under broad prohibitions against your country reason but not with Lisp age programs there are exceptions though to this rule thumb Libya which has a series of general licenses that allow for certain oil and gas transactions investment funds with minority interest from Libya government etc whereas list programs like Jim Bob ley and Venezuela are more traditionalist programs where the focus is just on ensuring the no party in an export import transaction is prohibited slide 11 comprehensive programs comprehending programs which we did go over a little bit in l'espace the comprehensive sanctions programs are Cuba Iran Syria Sudan North Korea and the region of primary Crimea however Sudan is temporarily suspended and will be revisited in July as of right now all transactions with regard to Sudan are authorized unless they are tagged under Darfur but if they are only tagged under the Sudan programs they are authorized comprehensive programs are broadly restrict exports and imports with countries or regions for US persons and persons subject US jurisdiction slide 12 this slide highlight the major preventive prohibitions under each of the comprehensive programs with one major exception the 2017 fine and rule which we just spoke about amends of Sudan sanctions regulations effective January 17 2017 again this is a nice simplified distilled version of the major prohibitions but it is while it is a nice slide to have and you will get the slides after the presentation you still need to check for the regulations there are they are nuanced they are complicated to make sure this isn't your Bible per se slice their team general licenses and exemptions this is another good slide for that highlight the exemptions and major licenses for each program again it is important to note that while the distillation of regulations into a PowerPoint is useful and illustrates broad ideas it is imperative to always read the regulations or call or write in for clarification at this point I think I'll hand it over to Vanessa good afternoon everyone my name is Vanessa dorincourt Thank You Zach for that information very informative and lots of useful slides that you can take back to your workplaces to review and share with others we're going to move on now to sanction compliance strategies and starting on slide number 15 sanctions compliance oh fak doesn't have a written requirement of regulation of requirement for a compliance program but we do expect that there is compliance that excuse me that entities that consultants or different industries are reviewing their policies and procedures for accuracy and for any potential violation but to prevent that from there's no one-size-fits-all for effect compliance program each program is uniquely tailored to your specific industry you have to take into consideration the risk and the situation please keep in mind that an enforcement action effective strict liability and enforcement action against your organization and will be to negative publicity and that's not something that you want so we're here to help you and provide some strategies so let's moving on to slide number 16 the basic pillars of an compliance program there are four pillars to the compliance program these starting with the first one is a risk assessment a risk assessment is is when you're evaluating the customer risk the product risk and the geographic risk the second is the internal control when you're screening your due diligence are you mitigating ever any risk the third is training and personnel how often are you training your personnel are the goals clear do they know what is expected of them and you have the right people in the right place to perform at an optimal level and lastly the independent testing and audit this is are you evaluating are you touching your program or you're identifying any areas of shortcoming and coming up with any types of radiation so quickly before we move on I want to talk about a little bit about the customer risk product with angiographic under risk assessment the geographic risk is exactly that a risk for the area it's transactions that either originate pass through or terminate in high-risk jurisdictions where they may be inadequate retik regulatory standards or there's a high risk for client corruption drug trafficking or terrorist activities we would affect covered that in some of the slides which slides 11 and 12 which you should be familiar with the discusses for jurisdiction you want to have an understanding or at least a familiarity of what type of business your customers in and with whom are they conducting these transactions what's their product why or is it originating where is it terminating is there possibility for it to be reacted to a sanctioned area these are all questions to ask and to have at the forefront when you're reviewing your policies and procedures moving to slide 17 so again it's important to have an understanding or at a minimum some type of familiarity with the various sanction program of the related export and import prohibitions which we presented for you in slide 12 and 13 and eyevac stated the information is ever-changing but slide 12 and 13 those charts there they're great to take back and keep them posted nearby so it gives you a template an idea of where transactions are allowed or what what is in what is not allowed and of course you could always call out a fact hotline if you have more questions also have an understanding of the property the assets that come within the US or the possession or control of a u.s. persons if they're to be lost or especially they can't be transferred out paid or dealt with um you have to have that understanding when you're conducting your risk assessment so you want to start by identifying areas of high-risk areas of high risk can be the size and location that's when you take into consideration your organization in your business the second is your customer base how well do you know your customers and the banking terms this is called know your customers kyc partners who are the partners or brokers your agent your intermediaries your suppliers who are your partners who are they doing business with the product are you confident in what the products are that you may be importing or exporting are you speculating make sure you have a good understanding of that and lastly the transaction the complexity of the transaction are these cross-border transactions and is there a potential for diversion simply stated potential diversion if they tell you they're going to one country but then there are eiected to another and you want to know where the products ending slide 18 the internal controls when I talk about internal controls it's two parts its your policies and it's your procedures the first part policy is outlining what the company should be doing or should not be doing and you want to make sure these are clear and your staff has an understanding of it and what's expected of them so your policies they can be broad or narrow they want to be clearly communicated and easily available create a call it creates a culture of compliance and ensure that your staff has seen support from senior management so compliance is not at just that lower level is at all and procedures it outlines these steps that the employees must take to ensure their compliance with policies and what they can do to mitigate any risk it can be step-by-step instructions for each process again this is contingent upon each person's responsibilities it would be specifically tailored to job function now procedures work in tandem with your policies procedures are easy to follow and often times you will ask your staff for assistance to help develop procedures your front line is usually I'm act on helping with this and designing distance they are like I said the front line and they are the ones dealing with this day in and day out moving on to slide 19 also discusses internal control screening what are you screening for if you're using effects sdn lift which is exactly flea touched upon in the beginning what are you screening for you're only looking at names of individuals and business owners of vessels that they may be using are you screening for addresses or only the country how are you screening it are you using a software tool again are you going directly to a fax web page and using the SDN are someone doing this manually and what are you screening for so are you screening how are you screening and what are you screening for and that is the foundation of an effective compliance program record-keeping are you researching your customers account their information their end user statement export licenses if it applies should good and straightforward documentation do you have these records this is also part of your due diligence do you have this information to know more about the products and where they're going or where they're coming from slide 20 we dive deeper into screening so we talked about the screen be SDN list out but also take into consideration screening documents as part of your due diligence here's a chart where we lay out common documents that you may see depending on your industry we have transportation documents failed documents financial documents so you're talking we're talking about your purchase orders your invoices your end-user certificate financial documents your payment methods again this all is relative to the type of business that you're in but this is a great cheat sheet so lack of better words on what kind of documents to take into consideration when you're screening are you looking for information on the SCMS or are you also looking for information within these documents that you may have available to you or perhaps your team someone else within the team has it available slide 21 training training is important because your staff needs to know what's expected of them they should also be familiar with affect sanction compliance you should have at least one qualified individual within all industries who is responsible for the day in and day out of the affect sanction compliance that individual you can have one you can have two they perhaps can wear several hats but at least one person should be familiar with it training is essential for all employees again from the top down frontline doesn't matter what part of the industry but training is essential the training and how often training is provided it's again based at risk assessment it's tailored specifically to your industry your line of work we do at least expect training once a year make sure the training goals are clear the objectives are clear and if there is shortcoming or any requires remediation that is attended to quickly and not allowed to progress and perhaps it becomes a bigger issue later on down the line so again training is essential 522 independent testing and auditing so what we want to look at here is what's the purpose of independent testing it's to identify any deficiencies within a compliance program and formulate corrective measures but one good strategy to keep in mind is when Oh feck has a recent action which you can see all of our actions are posted on our webpage under the recent actions page and have a quick look take a glance at what the situation was the penalty that may have been assessed and ask yourself are we privy to this can we do are we exposed to something similar to this so is there an area that we can change so learn from the mistakes of others is like I like to say with testing and auditing testing should be performed either internally by an outside auditor consultant or another qualified independent party it should be comprehensive enough to assess compliance with effect and make sure that the compliance program is specifically tailored to your industry the scope and frequency is based on your organization's risk assessment any internal changes and external changes so when we refer to internal external changes perhaps there are internal developments you have changes in personnel if someone leaves someone replacing them have they been trained maybe there's changes at the operational level perhaps you're offering a new product or a new service or your sales team is aiming at a new client base again take into consideration effects functions and is make a risk assessment organizational changes where their recent merge or reorganization external development any new sanctions programs that are announced by OFAC or changes to existing programs Zach mentioned at the start of our presentation the Sudan changed may go into effect in June on July 12 we are expecting updates as of July 12 so we encourage you to monitor our olfactory connection page and announcement - so we're all aware of what happens with the Sudan program the any new sanction tools that may be available in the market any published guidance that we may have or again as I mentioned earlier any oath by publishing forcement actions learn from the mistakes of others and like I stated remedial responses are you identifying any deficiencies that perhaps your outside auditors or your consultant pointed out are you responding to any pradhans patterns and trends that you can make some changes to now we're going to talk about enforcement overview as I stated earlier I look like a strict liability but let's talk about some of the steps that we take to get there so slide 24 this takes you through what our enforcement overview we have starting from left to right and a parent violation if there's an apparent violation and it's this close disclosed to effect in the form of a correspondence and we have the information gathering phase where we're going to either subpoena or send requests for information we're going to analyze the information that's submitted to us and there can be three steps starting with the no action or cautionary letter there can be a pre issuance notice the penalty or finding a violation sov stands for finding a violation or settlement and then lastly penalty notice or final tape or file finding of violation again most of our cases you'll see in the next few slides they end up in cautionary letters so if you turn to 525 from the bottom from again left to right no action letter is by severity leave severe then followed by cautionary letter finding a violation of civil penalty and or a criminal referral when we refer out to the Department of Justice or or other interagency partners comes to criminal referral slide point fix so deal what happens most often by volume as I stated no action letters or cautionary letters are a big part of our correspondence when we received a potential notice of an excuse me when we received a disclosure from the industry and the least common is a criminal referral that slides very easy to understand slide 27 so what do we take into consideration is effect enforcement guideline we will evaluate what we call general factors a to chain was their will for reckless conduct the industry knowledge of the transaction with their harm to sanction program objectives and individual and will take into consideration individual characteristics of the company to size specification and some of our administrative options when we're going to close a case is closing a case internally issuing a no action or cautionary letter again this comprises about 90 percent of our correspondence issuing a finding of violation or civil monetary penalty entering into a settlement we're making a criminal referral all the postings are on our webpage under recent actions I'm slide 28 is discusses our penalty this is some of last year I'm going to voted to time it adjust for inflation but this gives you an idea for each program trading with the enemy we I for narcotics the penalty a maximum penalty amount as of August 2016 for each transaction and of course the related relevant inflation factor so you can Colin gets pretty costly very defining a violation or assessment of a title team slide 29 the effects enforcement overview I said it and I'll repeat it one more time we publish our information on our web page under the civil penalties and enforcement page and companies can gain valuable insight or lessons learned from mistakes of others so you wanted when reviewing these take into consideration what led to that apparent violation is your company engaging in the similar type of conduct does your company share similar risk factor what controls view combined controls do you have within your organization and what compliance deficiencies may have occurred that is going to take us into resources that are available to industry starting with slide 31 all right so thank you very much 5:31 starts all of our resources o fact has a wide variety of tools put public to use for instance this page a lot of our web-based products including the recent actions page where we post felony cases designations etc we also have provided our Sdn search tool which can be useful in determining a false positive however I believe this will be sent out in PDF form so I'm not sure if the links will work but the if you just go to Treasury gov and at the top of the page it should have a reece trying to find really note on it should say resource center and it will have a drop down when you click on financial sanctions and that will be the page where you will have the entirety of effects free to the public tools and slide 32 this highlights probably one of the more important web pages we have the recent actions page that's where we post designations will post penalty cases there anything public the cofactors will be on recent actions we also have the misting research tool and recent actions welcome to the 21st century and you can sign up for email updates so anytime we post something to recent actions you will get an email update and if you look at the dates there in March we had four we might have more than that so as so between March seventh and March 17th we had four emails that went out so we're not bombard you with emails it's only the it's only the imperative stuff that we post some recent actions you won't get 50% off deals slide 33 is the Resource Center that's what I was discussing earlier you can find it simply by going to Treasury gov under the Resource Center tab at the very top of the page will be a drop-down click on financial sanctions that's everything related to OPEC that you need the SDN search tools on there the licensing pages on there fa Q's are on there so that would be a good place to start and finally hope that contact information and again the slides and priests will be sent out so you don't have to write Donal but if you you can also just simply Google cofac contact information and our phone number will pop up we are one of the more accessible government agencies as far as through the phone goes and we do man the phones and the email every day so if you're not getting an answer there might be something wrong maybe you're emailing go through maybe a phone call and go through so don't be shy you can pull back I do want to thank you very much for your time we will open the floor up to questions at this point great thank you second Vanessa operator can you remind folks how they can get into the queue for questions currently if you'd like that professional phone line please press star-1 make sure your phone is unmuted record your name at the prompt and while we wait I have a quick question Vanessa and Zach oftentimes companies will review the country sanction program for a particular country and still have some questions as to whether our uncertainty as to whether or not they need to apply for a license what is your recommendation for their next step to contact you guys via email and phone and sorry so you asked that you stated that oftentimes companies will review our sanctions page for extension with certain countries so a country they will read through the specific country sanctions and have a question I shall have a unclarity unclarity as to whether whether their company needs to apply for a license whatever to get a connection yes so they would call in our hotline then would give us some details preferably the more information the better so that we can make an assessment on whether or not there's a general license for the activity perhaps they may have overlooked it I know the the webpage has a plethora of information so perhaps there's a general license and because we do this day in and day out we have more knowledge on that we can share that information but if there's not then we can direct them to apply for a license but hotlines always available exactly one time minute yeah just real quick and if the question is particularly complex it's better to write into the Oh feck underscore feedback at Treasury Jonathan I don't know if you can put that slide 34 back up just so everybody can get the contact info there is an underscore no fact feedback at trader Iago if it's complex go ahead and write in we do answer and if it's I mean it's up to you whether you're going to determine its complex or not but if it's a simple GL question or maybe a more complicated remittance question or a simple Espeon question you can call in but either way we'll get back to you great thank you and we had a question come in over the written queue which is how often should recipient a company be screened how often again it's a risk assessment we cannot tell them to screen once a week once a month there's always changes the changes can happen at any time when I say changes that's updates to the SDN list everything from additions to the SCN list to remote the removal of names this can happen at any time so I would recommend something that's relevant to their unique to their organization if they are dealing with high-risk entities or high-risk areas then perhaps more often as opposed to your industries that may not be dealing with high-risk entities and they do everything domestic so again it's a risk assessment and it's specifically tailored to the side and complexity when the products that they offer great thank you an operator did we have any questions coming over the audio queue I guess we do have one question in queue currently that's from Roger Bartholomew your line is open yeah yeah question on the slide shows we were told that the last one that we would get copies and I never have received a copy and you should I talk to you to make sure I'm getting copies of these presentations you should have received that sir you can email me following this presentation we can get that rectified your email addresses any invite yes it is it's Melissa Grasso at trade.gov all right thank you operator do you have any other questions in the queue at this moment there are no other questions Zac Vanessa thank you guys again did you have any actually I'm sorry we had one more question come in over the written queue the question is we are currently exporting to Syria from Canada with the OPEC rules still apply I need to reach me a little more information as a US company or the US persons involved you're its currency involved is a transiting US bank if the person who asked that question actually the answer is yes yeah I'm not sure yes to all if the person if you'd like to hit star one it might be easier to have this as a discussion versus over the written queue and again as a reminder please press star 1 and record your name to ask any questions over the phone line we do have one in queue it will just be a moment [Applause] in our next question comes from Jen Lee your line is open hi I'm the one that posted the question about shipping from Canada sure Cara is visit a US company yes were the US company and there's the the pay mention section is a u.s. ballast and it's just the product originated from Canada yes subject yes it sounds like um and again you can write in and we can discuss this further but it does sound like you would be subject to sanctions or regulations and regulations so if you look at slide number five but that covered at the beginning it talks about basic juice effectors diction and it's us right in the middle us entities us incorporated entities and transactions directly or indirectly that involves the United States or us person that within itself let's you let you know that if the u.s. person is involved then they must comply with effect sanctions if you want to call into the hotline evacuated or right in your welcome to we do ask for more information but keeping it very simple and for everyone the u.s. person was involved you are subject to affect compliance okay so which one should I call contact information our contact information is on slide 34 and it's described despite its currently active okay the phone number is 182 three numbers one eight hundred five four zero six three two two I repeat one eight now or email at mail all effects feedback correct Oh FAQ underscore feedback at Treasury dot gov and again you'll be getting these slides following the presentation okay thank you thank you I prefer appraiser other questions there are no other questions at this time I was just about to give a reminder but if you would like to ask any questions over the phone line please press star one and record your name you we do have a question coming through it'll just be a few moments great thank you our next question comes I'm Jordan your line is open yes sir thank you but I'm primarily with defense trade ITAR you know electrical licenses with B D G C or for some items Commerce if I get approval on up you know D sb5 not that I need to also ask approval on one of your licenses for the transaction if the transaction involves Iran then then yes you want to make sure we have a general license we would need more details again your your question is a bit more specific that was just a hypothetical you know any one of them is that it go through the State Department for approval and put in a certain license okay defense commodities and they approve it with based on whatever criteria maybe it would you also need an additional Google from you with the same transaction I think in a majority of cases probably not but again each program is different so you're dealing with Iran you would need to deal with Outback that are other programs where you're in Austrian security is in charge of exports there's a lot of instances where customs and border protection would be would have jurisdiction over imports but when you are dealing with any comprehensively sanctioned program excuse me country you may want to at least give us a call to double check and cases where it's not conferences comprehensively sanctioned you would want to make sure you're not dealing with an SDN right um of course and around new licenses are there any special registration requirements or how does it how does your licensing process work in the real estate department kind of i2r centric they have certain requirements that you'll have registration requirements or special licensing requirements at all so our licensing application so let's just go back to we're all on the same page you're referring to ITAR which specifically deals with iran for those that are also listening in and are not familiar with that um so there's two OPEC has jurisdiction it's a sanctioned country so you do have to go through Colfax and because you're referring specifically to defense items you also have to go through Bureau of Industry and Service to commerce so with l5 the licensing application is something you would complete online it's you it's a stated in application where you would provide details about your organization and details about whom we plan on doing business with and the product there's an arrogance section which is open for your complete description the more information for our licensing officials the better it is on a fewer item is an e AR 99 and you have that type of information you would go ahead and put that in the narrative and that's again if you're required to have a specific license whether or not you require a specific license depends on on your products and that's something that we wouldn't dive into on a webinar we would dive into that in more detail through a phone call but as I were saying you'd have to apply for a license if you're required to apply for a license you complete all the details on your product and who you're conducting business with Amy narrative portion and the licensing officer would then review it and if they have additional questions they would follow up directly neither one of us is with licensing so we cannot answer more questions and more specific questions about the licensing process we are with compliant we'll be happy to discuss that offline if you need more details and I appreciate it thank you you're welcome and another quick question which is what is a time frame to get approval on a license and that's the question of the day we get that all the time we like to say there's no specific timeline it depends on the complexity the details and the sanction program and any current policies or foreign policies that the administration is taking into effect taking into consideration what we like to stay on the line you can take a minimum 90 days sometimes longer there are licenses that sit there a little longer it depends on the complexity and the details provided if you provide an application where you're just saying your name and your product and you're not saying anything else that you're saying hey I'm going to ship this out to Iran or Cuba and you're not giving any more details and of course the licensing officer is going to ask for more information but that will just prolong your process so on to make sure you provide more information so that's the answer there's no definite answer an operator will do one final check for the audio cue okay once again if you would like that question from the phone lines please press star one and record your name the questions quite well again Vanessa and Zak thank you so much for for lending your expertise today encourage folks to either call the OFAC hotline or email the OFAC feedback line with any further questions any specific questions again you will be getting a net replay of this webinar as well as the slides within 24 hours so thank you again and have a great afternoon thank you thank you thank you for your participation in today's conference you can have