22 CFR §120.9 defines a Defense Service as furnishing of assistance including training, to foreign persons in the U.S. or abroad. A defense service encompasses the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing or use of defense articles. Additionally includes military training of foreign units and forces which [...]
Posted on October 27th, 2011 by admin
Filed under: ITAR | Comments Off
If you’re a responsible ITAR exporter, record keeping is far and away your best tool to avoid fines and penalties from an audit. The goal of good record keeping is simple: Fulfill your legal obligation as an exporter and ensure success and minimal impact on your business in the event of an audit. Earlier this [...]
Posted on October 14th, 2011 by admin
Filed under: ITAR | Comments Off
After registering with the DDTC, ITAR certification is a self-certification process. That means that there is not an official “certification” requirement spelled out in the regulations. As an exporter you are expected to maintain compliance with and knowledge of ITAR regulations. A formal export compliance policy and ongoing training are both highly recommended by DDTC [...]
Posted on September 23rd, 2011 by admin
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Authorizations to transfer defense articles and provide defense services can help meet the legitimate needs of friendly countries. However, the U.S. strictly regulates exports and re-exports of defense items and technologies to protect its national interests and peace and security of the broader international community. There are 60 exemptions established in the International Traffic and [...]
Posted on July 11th, 2011 by admin
Filed under: ITAR | Comments Off
The U.S. Government views the sale, export, and re-transfer of defense articles and defense services as an integral part of safeguarding U.S. national security and furthering U.S. foreign policy objectives. The Directorate of Defense Trade Controls (DDTC), in accordance with 22 U.S.C. 2778-2780 of the Arms Export Control Act (AECA) and the International Traffic in [...]
Posted on June 14th, 2011 by admin
Filed under: ITAR | Comments Off
The US Department of State has amended the International Traffic in Arms Regulations (ITAR) to create a new exemption for intra-company transfers that involve dual or third-country nationals. This is in response to last year’s proposed rule to eliminate the separate licensing requirement for dual national and third-country nationals employed by licensed end-users. The comments [...]
Posted on May 19th, 2011 by admin
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An export license, issued by the U.S. government, is required to transfer of technology, software, and equipment to non-U.S. persons. As part of an export license, the government attaches riders and conditions that all parties to the license must satisfy. An Internal Control Plan (ICP) communicates how the requesting company and other parties to a [...]
Posted on April 26th, 2011 by admin
Filed under: ITAR | Comments Off
An important issue facing defense contractors today is exactly how much information should be shared with the Government about internal deficiencies with an import/export compliance program. Empowered Officials (EOs) and corporate executives are often uneasy about opening doors through which enforcement agencies may pass and ultimately cause irreparable harm to the company, its reputation, and [...]
Posted on February 1st, 2011 by admin
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Globalization, terrorism and threats of proliferation have led to an increase in the enforcement of U.S. export control laws by the federal government. These laws provide for severe civil and criminal penalties for the unauthorized disclosure of sensitive technology to foreign citizens. Technology-related clients of all sizes are increasingly finding themselves in violation of such [...]
Posted on May 14th, 2009 by keeton
Filed under: EAR, ITAR | Comments Off
A reader recently asked me: There has been a question of cell phones with cameras in them. Is there a policy or a standard practice we can incorporate? Should we have all guests and employees leave them in their cars or store them in specified places? Off the top of my head, there are three [...]
Posted on May 11th, 2009 by keeton
Filed under: ITAR | Comments Off
