5 year maintaining practice on export records

January 16, 2014 Federal Register notice. The BIS is allotting until March 17, 2014 for both the general public and Federal agencies to address the 5 year maintaining practice on export records regarding “memoranda, correspondence, contracts, invitations to bid, books of account, financial records, restrictive trade practice or boycott documents and reports.” The BIS is [...]

Final Rules of the ECR implementation process

As issued by the Dept. of Commerce Federal Register in their original notice, the following is to be regarded in the first two Final Rules of the ECR implementation process effective Oct. 15, 2013: -Added “structure and related provisions to control munitions items that the President has determined no longer warrant export control on the [...]

ITAR Compliance

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 [...]

$50,000 in ITAR fines

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 [...]

ITAR Exemption Codes

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 [...]

What is a Defense Service?

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 [...]

ITAR Recordkeeping

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 [...]

ITAR Certification

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 [...]

ITAR Export Exemptions

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 [...]

Export License Requirements

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 [...]