Export Control Notice

Overview

Phantom Array passive bistatic radar technology is developed and manufactured by Junker & Douglas, Inc. in the United States. Certain components, technical data, and associated information may be controlled under U.S. export control regulations.

Junker & Douglas is committed to full compliance with all applicable export control laws and regulations. We conduct all international activities in accordance with the requirements of the U.S. Department of State, U.S. Department of Commerce, and other relevant regulatory authorities.

Applicable Regulations

Phantom Array technology may be subject to the following U.S. export control regimes:

International Traffic in Arms Regulations (ITAR)

The ITAR, administered by the U.S. Department of State's Directorate of Defense Trade Controls (DDTC), controls the export and temporary import of defense articles and defense services. Radar systems and related technical data may be controlled under the United States Munitions List (USML), particularly:

• Category XI — Military Electronics
• Category XII — Fire Control, Laser, Imaging, and Guidance Equipment

Export Administration Regulations (EAR)

The EAR, administered by the U.S. Department of Commerce's Bureau of Industry and Security (BIS), controls dual-use items that have both commercial and military applications. Relevant Commerce Control List (CCL) categories may include:

• Category 6 — Sensors and Lasers
• Category 7 — Navigation and Avionics

Compliance Requirements

All parties engaging with Phantom Array technology must adhere to the following requirements:

• No Unauthorized Transfers: Technical data, hardware, and software may not be disclosed, transferred, or re-exported to foreign persons or entities without prior authorization from the appropriate U.S. Government agency.
• Foreign Person Restrictions: Access to controlled technical data by foreign nationals—including those present in the United States—requires a valid export license or applicable exemption.
• End-Use Monitoring: All authorized exports are subject to end-use verification and may require post-shipment reporting.
• Denied Parties Screening: Junker & Douglas screens all customers and partners against U.S. Government restricted party lists prior to any transaction.

Foreign Customers

Sales and technical disclosures to foreign governments, foreign commercial entities, and international organizations require appropriate export authorizations. This may include:

• Direct Commercial Sales (DCS) licenses issued by DDTC
• Foreign Military Sales (FMS) through the U.S. Government
• Technical Assistance Agreements (TAA) for ongoing support
• BIS export licenses for dual-use items

Five Eyes (FVEY) and NATO partners may benefit from certain license exemptions, though authorization requirements vary based on the specific technology and end-use.

Penalties

Violations of U.S. export control laws may result in severe civil and criminal penalties, including:

• Civil fines up to $500,000 per violation (ITAR) or $300,000 per violation (EAR)
• Criminal fines up to $1,000,000 per violation
• Imprisonment of up to 20 years for willful violations
• Debarment from future export activities
• Seizure and forfeiture of goods

Voluntary Disclosure

Junker & Douglas maintains a policy of voluntary self-disclosure for any potential export control violations. If you become aware of any unauthorized disclosure or transfer of Phantom Array technology, please contact our compliance team immediately.

References

For more information on U.S. export control requirements, please consult the following resources:

• Directorate of Defense Trade Controls (DDTC)
• Bureau of Industry and Security (BIS)
• ITAR (22 CFR 120-130)
• EAR (15 CFR 730-774)