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How to use the Deemed Export Determination Engine (DEDE):

The Company’s Tool for Processing Job Seekers & Employees Covered by the Deemed Export Rule

Overview: The International Trade Compliance Group (ITC) is responsible for the development, implementation and monitoring of the Company’s internal control program for trade compliance as defined under COBC. According to the U.S. Department of Commerce, a deemed export represents the release of any technological information of U.S. origin to any person other than a U.S. citizen, wherever the transfer occurs.

The Deemed Export Rule:

• U.S. origin technical information, not goods, must be involved. Transfer of that information is to a non-U.S. citizen or green card holder.

o Technological information is any information to reproduce the end-product such as:

Printed Material & Manuals (verbal or physical)

Technical Information & Software

Drawings & Papers

• When assessing any transaction for compliance, with specific regard to information created or written by a U.S. citizen or green card holder inside or outside of the U.S., three areas must be considered:

Who is receiving the information?

What is the nationality of the recipient?

What technology is being exported?

Click the link to view a list of Sanctioned Countries that are generally restricted from receiving U.S. origin technological information. The International Trade Compliance Group (ITC) will make the hiring suitability determination for any candidates that are from the listed sanctioned countries. In which case, ITC will submit the application for the license, where needed.

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Accessing DEDE

The Deemed Export Determination Engine (DEDE) assists the user in determining if an existing foreign national employee or a potential foreign national candidate is required to obtain a license from the Department of Commerce based on the Deemed Export regulations. The Deemed Export rule comes into effect when technology is “deemed” to be provided to a foreign national while accessing US technology. DEDE, which was designed by the International Trade Compliance (ITC) group, takes into account nationality, citizenship, job code, and accessibility to certain technologies in determining whether or not the person is required to obtain a license. The tool will be used in conjunction with the legal opinion of the ITC to make the final determination of the license requirement.

Identification of Candidates who need to be run through the Deemed Export Determination Engine (DEDE)

The identification of candidates to be inputted into the DEDE should be done after the candidate has accepted the offer. An HR professional involved in the recruiting process should acquire a definitive understanding BEFORE sourcing a position of whether the hiring manager is open to undergoing the process, should a foreign national meet the qualifications of the job ( i.e. holding the requisite knowledge, skills, and abilities.)

New Hires/Transfers

The HR professional should review the candidate’s response to the question, “Will you now or in the future require employment visa sponsorship?” If the candidate answered “no”, there is no need to run the candidate through the Deemed Export Determination Engine (DEDE). If the candidate answered “yes” to this question, the candidate must be entered into the DEDE for review.

Internal Promotions

Employees being promoted from a non-technical to a technical job title that is covered under the deemed export rule should be entered in the DEDE. The HR professional should use their discretion in determining candidates who if promoted, could potentially be in violation of the deemed export rule. In this case, the HR professional should enter the candidate in the DEDE for review.

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5 Steps to Processing a Candidate’s Information in the Deemed Export Determination Engine (DEDE)

1) To begin, download the US Export Questionnaire (shown below) from the DEDE homepage. Send the questionnaire to the hiring manager to complete. The manager will send the completed form back to HR. This information must be used to complete the candidate’s information in the DEDE fields.

Example: US Export Questionnaire

Note: For sanctioned country candidate, download the Pre-Screening Questionnaire for Employment from the HalWorld ITC DEDE homepage. Send the questionnaire forms to the HR In Charge, Candidate and Hiring Manager to complete. The HR will send the completed form back to FHOUDEDE for analyzing.

2) On the DEDE homepage, click the ‘Enter DEDE’ button. (You may need to login using your network information if single sign-on does not function.)

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If you need to login using your network information, a new screen will appear displaying the SAP NetWeaver log on portal. Click and another screen will prompt you to input your username and password.

Click to enter the Deemed Export Determination Engine (DEDE).

3) Begin the screening process using the employee’s data taken from the US Export Questionnaire.

a) Enter the SAP ID for Transfers and Rehires.

Note: If there is a SAP ID, enter that information first and click which will auto populate the other fields based on that individual’s information in ESS. Please check the auto populated information and compare with the data provided on the US Export questionnaire. Change as necessary to reflect the candidate’s new information.

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b) For New Hire candidates, fill in the five mandatory fields (*) on the DEDE screen.

1. Name : Type the first and last name

2. Job Code:

Clicking on the search icon will allow the user to search for the job code by the Object ID NMBR or by Name using an * before and after the given job name. Click button to narrow your search options. When the

correct job number/name is selected, click to transfer that information onto the DEDE screen.

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Job Code Search Screen

3. PSL:

Click in the PSL field. A screen will appear displaying all the available PSL names, click , scroll down and choose the candidate’s specific PSL area. Then click to transfer that data onto the DEDE screen.

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4. Destination / Work Location:

Specify the work location for the candidate. As an example, for candidates who will work in the US, type ‘US’ in this field.

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5. 1st Citizenship:

Some individuals will have citizenship in more than one country, so always use the candidate’s most recent citizenship/permanent residence (country) in this field.

Once all information is populated, click to view the results on the DEDE spreadsheet. A new screen will appear, whereby HR will need to process the resulting information.

Processing the DEDE report

In the ‘View’ drop down box, choose ‘GlobalLayout’ as the spreadsheet’s setting.

Always click button before proceeding. A record will then be created that will be sent directly to ITC for audit purposes.

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Depending on the color of the ‘Status’ column (red/green), the HR professional will export the data to an excel spreadsheet and send to the hiring manager for review.

Deemed Export Screen

All Green Status:

If the ‘Status’ column is all green the there is NLR (No License Required) for that candidate (as shown below).

Export the data to an excel spreadsheet; do not export data to ‘Print Version’ (pdf).

Send the excel spreadsheet to the hiring manager and to the US Immigration Functional mailbox (with supporting visa documentation). Use the following naming convention for the excel spreadsheet and the subject line of the email:

a) New Hire: ‘New Hire_Jane Smith_Deemed Export Screening’

b) Transfer / Rehire: ‘012345_Joshua Arbol _Deemed Export Screening’

Note: Use the email template shown in the ‘Email Template’ section on this job aid.

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Red/Green or Red/Red:

If the ‘Status’ column is all red (or red and green ), more information from the hiring manger will be required based on the ‘Job Type Concern’ and ‘Condition’ columns.

** Note the example below. The manager will have to answer ‘yes’ or ‘no’ based on the employee’s need to have access to explosives, detonators, etc. **

Export and save the data to an excel spreadsheet using the naming convention below:

a) New Hire: ‘New Hire_Jane Smith_Deemed Export Screening’

b) Transfer / Rehire: ‘012345_Joshua Arbol _Deemed Export Screening’

.

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Before sending the spreadsheet to the hiring manager, delete all rows having blank spaces in the ‘Job Type Concern’ column. If there are duplicates in the ‘Job Type Concern’ column, only ONE should be kept and the other corresponding rows deleted. DO NOT use any other column to determine whether a row should be deleted. Save any changes made before attaching to designated email correspondence.

Note: Use the email template shown in the ‘Email Template’ section on this job aid.

Email Templates

The International Trade Compliance Group has provided two email templates that are used when sending the hiring manager a candidate’s DEDE results.

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• All Green Scenarios

Send to the Hiring Manager and copy the US Immigration Functional mailbox with the excel file attached.

(Hiring Manager),

I have reviewed the case for xxxxxxxxxx, and find that the candidate will not need any IVLs to perform job functions.

• Red Scenarios

Send to the Hiring Manager with the excel file attached.

(Hiring Manager),

I have reviewed the case for xxxxxxxxxx, and have provided my findings on the attached excel spreadsheet. In order to process in an efficient manner, you will need to mark either ‘yes’ or ‘no’ in the appropriate columns to denote whether or not this candidate will need access to technical data with respect to each area of concern where the Status column is red.

Please save changes and send a reply to me.

According to § 740.17(a) (1) of the EAR, a deemed export license for 5D002 (Laptops, servers, or any hardware with controlled software) or 5E002 (source code) content would not be required providing this person is a true Halliburton employee and not a contractor.

If the job functions change and they require access to the above listed exceptions, a license will have to be applied for and there is no guarantee it will be approved. Please obtain confirmation from either the hiring manager or employee that they understand the conditions above.

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Email Subject line:

(New Hires) New Hire_John Smith_Spain_Deemed Export Screening

(Transfers/Rehires) 012345_John Smith_Spain_Deemed Export Screening

Hiring Manager [HM] response scenarios (for red conditions only)

If the HM answers ‘No’ to all red status conditions and job type concerns, forward the US Export Questionnaire and the HM responses to the US Immigration Compliance.

If the HM answers ‘yes’ to any red status conditions and job type concerns, forward the response(s) to the International Trade Compliance functional mailbox for further review.

ITC will review and correspond with the hiring manager to determine if the candidate will or will not require access to any relevant technology.

o If ITC determines that the candidate will not be required access to the relevant technology, ITC will send the results to the HM and HR.

o HR forwards the ITC results to the US Immigration Compliance functional mailbox.

If access to the technology is required as determined by the ITC, they will process an application for the necessary export license per the condition/job type concern requested by the hiring manager for the foreign national candidate.

o Note: This process can take up to 8 weeks before the license is granted.

For further instructions, follow the US DEDE Process Map.

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