Trade compliance is not just a requirement - it is central to how we operate as a responsible global company.

• 100% Commitment – Full compliance with all U.S. export, import, and sanctions laws and regulations.
• Global Screening – Every transaction is screened against U.S., EU, and UN restricted party and sanctions lists.
• Zero Tolerance – No participation in unsanctioned foreign boycotts.
• Responsible Trade – Accurate product classification, country-of-origin reporting, and customs valuation.
• Employee Awareness – Mandatory training for all staff, with annual refresher training.
• Speak Up – Immediate reporting of concerns encouraged company wide.

At Rochester Electronics, LLC, trade compliance is a fundamental part of our responsibility as a trusted global supplier. We are fully committed to complying with all applicable laws and regulations governing the export, re-export, import, transfer, release, sale, or disposal of U.S. export-controlled products, technical data, and technology.

We recognize that “exports” are more than just the physical shipment of goods. They also include the transfer of controlled information to foreign nationals—whether by email, phone, presentations, or customer interactions. Under no circumstances will Rochester Electronics conduct exports in violation of U.S. regulations or our internal compliance policies.

Our Compliance Framework

Rochester Electronics’ Trade Compliance Program is designed to meet the requirements of:

• International Traffic in Arms Regulations (ITAR)
• Export Administration Regulations (EAR)
• Office of Foreign Assets Control (OFAC) Regulations

Adherence to these regulations is a mandatory condition for participating in all international programs. We dedicate the necessary resources to prevent violations and to maintain continuous compliance.

We expect all employees, suppliers, distribution partners, customs and business associates to uphold these standards and to act with integrity and professionalism in all trade compliance matters.

We also understand the serious consequences of non-compliance, including criminal or civil penalties, substantial fines, exclusion from global programs, and reputational harm. Our commitment to compliance ensures we remain a responsible and reliable partner to our customers worldwide.

Sanctions & Restricted Party Screening

To ensure compliance with global sanctions:

• All transactions are screened against applicable restricted party lists (U.S., EU, UN, and others).
• Rochester Electronics will not engage in business with any individual, entity, or country subject to comprehensive sanctions.

BIS 50% Rule (also known as the Affiliates Rule)

Rochester Electronics is committed to full compliance with the Export Administration Regulations (EAR) and all BIS requirements, including the Affiliates Rule. We will not export, re-export or transfer items subject to the EAR to any entity that is subject to Entity List / MEU list restrictions unless a required BIS license has been obtained or a valid license exception applies. 

Anti-Boycott Compliance

In line with U.S. anti-boycott laws:

• We do not participate in unsanctioned foreign boycotts.
• We screen all transactions for potential boycott-related compliance issues.

Export & Import Compliance

Our products are subject to U.S. export control laws. They may not be exported or re-exported to certain restricted countries or denied parties, including those on the Department of Commerce’s Entity List.



We also exercise reasonable care in import activities, which includes:

• Accurate product classification under the Harmonized System (HS) code
• Correct country-of-origin determination
• Accurate customs valuation
• Maintaining detailed import records as required by law

Training & Awareness

Compliance is everyone’s responsibility. To ensure awareness and accountability:

• All new employees complete comprehensive export control training.
• Annual refresher training is mandatory for all staff.
• Training covers export awareness, red flag identification, anti-boycott regulations, and reporting obligations.
• All training is delivered and tracked through our Learning Management System (LMS).

Reporting Potential Violations

We encourage immediate reporting of any suspected trade compliance violations. Concerns can be raised directly with Rochester Electronics’ Trade Compliance leadership.

We maintain a strict non-retaliation policy: no employee will face retaliation for reporting a concern in good faith.

Resources and Links

U.S. Bureau of Industry and Security (BIS) – www.bis.doc.gov

U.S. Customs and Border Protection (CBP) – www.cbp.gov

U.S. Office of Foreign Assets Control (OFAC) – www.ofac.treasury.gov

Contact Information

TradeCompliance@rocelec.com