The phrase “ITAR Compliance” gets thrown around a lot by defense contractors, ITAR exporters and other regulated businesses, but they’re not always using the same definitions. If your exports are controlled by the Department of State and are subject to ITAR regulations (meaning that your product, service, or technology is listed on the United States [...]
Posted on April 22nd, 2012 by admin
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Last Thursday the Department of State issued a press release detailing charges and penalties levied against Alpine Aerospace Corporation and TS Trade Tech Incorporated of New Jersey. Both companies share common ownership and provide replacement parts to the aerospace industry. Violations: Failure to obtain proper export licenses Improper citation of existing licenses Failure to obtain [...]
Posted on April 9th, 2012 by admin
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Here’s a list of ITAR exemptions that may apply to your product. Please note the date of this article when using the table. DDTC ITAR Exemption Codes Code Description 123.4A1 22 CFR 123.4 (a) (1) Temporary import of U. S. – origin defense items for servicing, inspection, testing, calibration, repair, overhaul, reconditioning, or one-to-one replacement [...]
Posted on March 1st, 2012 by admin
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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
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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
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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
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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
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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
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