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Comtech
Mobile Datacom Corporation Export Compliance
As
one of the leading manufacturers of satellite-based
tracking and messaging solutions using state of the
art transceivers, Comtech Mobile Datacom Corporation
(“CMDC”)
is committed to full compliance with all export control
regulations administered by the U.S. Department of Commerce,
the U.S. Department of State, and other U.S. regulatory
agencies. CMDC has implemented a detailed export control
policy and export compliance program to ensure that there
is no illegal diversion of CMDC’s high technology
commodities and technical data to military, terrorist,
or nuclear/missile/chemical weapons proliferation activities
through the export or re-export of CMDC’s products
or technology in violation of any U.S. law. The export
control policy and compliance program has the full support
of CMDC’s senior management.
Export Control Statement
Each sales order acknowledgement and commercial invoice
issued by CMDC contains the following statement:
CMDC DOMESTICALLY SHIPS AND/OR EXPORTS THESE COMMODITIES,
TECHNOLOGY OR SOFTWARE FROM THE UNITED STATES IN ACCORDANCE
WITH THE EXPORT ADMINISTRATION REGULATIONS. DIVERSION
CONTRARY TO U.S. LAW IS PROHIBITED.
Jurisdiction
The US Department of Commerce (DOC) and US Department
of State (DOS) are the principal U.S. Government organizations
that review and classify CMDC products. Based on formal
reviews completed to date by either appropriate authorities
within these departments or our legal counsel, the determination
is made that CMDC’s current products are primarily
subject to the Export Administration Regulations (EAR)
administered by the DOC’s Bureau of Industry and
Security (BIS). The EAR is available at http://www.bis.doc.gov/
CMDC will continue to review new products to ensure their
proper classifications and will consult with legal counsel
or the U.S. Government to ensure that these product classifications
are up-to-date and correct.

| Export
Classification Control Number (ECCN) |
| Product |
ECCN |
Country
Chart Column |
License
Exception Available |
Notes |
| Transceivers,
RF Products, Modems, and Digital Accessories. |
5A991 |
AT1 |
NLR |
Please
refer to the EAR for export guidelines |
Computers
for use with CMDC Transceivers:
2050-0003: Laptop Computer;
2050-0018: Magnus MTS Tablet Computer
2050-0002: Amrel Patriot Rugged Tablet Computer |
4A994 |
ATI |
NLR |
Please
refer to the EAR for export guidelines |
Mapping
Software:
SW-0017: MTS Version 5 V2 Paravant Windows
NT 20GB;
SW-0019: MTS Version 5 CS NCS CY25 Windows
XP 20GB |
5D992 |
ATI1,
AT2 |
NLR |
Please
refer to the EAR for export guidelines |
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Questions regarding the applicable ECCN for
a particular CMDC product may be referred to CMDC’s
Export Control Group at exportcontrols@comtechmobile.com

CMDC makes no representation or warranty as to the
accuracy or reliability of the above information. Any
use or reliance on such classifications is at the user’s
own risk and without recourse to CMDC. CMDC is in no
way responsible for any damages, whether direct, consequential,
incidental, or otherwise, suffered by the user due
to use or reliance on such classifications, for any
purpose whatsoever.
Prohibitions
Embargoed/Sanctioned Nations:
The U.S. Department of Treasury, Office of Foreign Assets
Control (OFAC) maintains the listing of nations under
embargo or sanction. Please refer to the OFAC web address http://www.treas.gov/offices/eotffc/ofac/,
for additional details.
CMDC products are prohibited from being shipped to the
following countries:
• Cuba
• Iran
• North Korea
• Sudan
• Syria
CMDC’s products or technology may not be exported
to any country listed by OFAC unless specifically permitted
by the U. S. Government under an official export document.
Prohibited Parties Listings:
The U.S. government regularly publishes and updates lists
of persons and companies that are denied access to U.S.
exports. These lists are accessible through the DOC/BIS
web address http://www.bis.doc.gov/,
under Exporter Resources – Lists to Check:

| Denied
Parties |
DOC
(BIS) |
| Unverified
List |
DOC
(BIS) |
| Entity
List |
DOC
(BIS) |
| Special
Designated Nationals (SDN) |
US
Department of Treasury (OFAC) |
| Debarred
List |
DOS |
| Nonproliferation
Sanctions |
DOS |
| General
Order 3 to Part 736 |
DOC |
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If an individual or company appears on any of these lists,
CMDC will not permit any of its products or technology
to be exported by or to that individual or company, unless
CMDC receives U.S. government authorization for export
or re-export.
Limitations/Prohibitions:
The U.S. Government administers export controls on certain
products to certain destinations for national security
purposes. Exporters of such products may be required
to obtain export licenses from the U.S. government prior
to exportation. In addition, the Government places limitations
on the export of products that could be used in some
of the following activities:
• Missile technology
• Foreign military applications
• Nuclear proliferation
• Drug trafficking
• Terrorism
Please refer to EAR Part 736 for more details at web
address http://www.access.gpo.gov/bis/ear/ear_data.html
Violations
CMDC’s Export Controls Group will report any known violations
of U.S. export control regulations to the appropriate
government agencies:
• Bureau of Industry and Security, Office of Export
Enforcement (OEE),
• Department of Homeland Security, U.S. Customs
and Border Protection (CBP), or
• U.S. Department of State. Directorate of Defense Trade Controls.
Customer Purchase Order Requirements
All customer purchase orders sent to CMDC must include
the following:
• End User Name (Address if available)
• End Use Country
• Clear (Foreign) Ship To Address (if goods are
for export)
Note: All Exports from the U.S. require a commercial
invoice. CMDC will not release shipments to freight forwarders
or carriers without a CMDC commercial invoice or drop
ship document provided by the customer.
Questions/Contacts
CMDC’s Export Controls Group is available to respond
to questions or concerns. Please address any correspondence
or inquiries to the following empowered official:
David A. Ulanow, Director of Contracts
Phone: 240-686-3325
Fax: 240-686-3301
Email: david.ulanow@comtechmobile.com
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