Responsibility, integrity, community, and excellence. The ddtc requires all registrants to have and maintain an export compliance manual. The itar frequently asked questions guide contains answers to over 70 questions most often asked by exporters who are regulated by the. Department of state, directorate of defense trade controls ddtc. Let me set the stage for this series of tutorials on international traffic in arms regulations or itar. This manual is an example and is intended only as a guide. International traffic in arms regulations itar the itar requires manufactures of products that fall under the united states munitions list usml to register as manufactures and.
The international traffic in arms regulations itar are part of a web of laws and regulations prohibiting u. Attachment 10 customer itar notification customer itar notification letter dear customer. Control act aeca and the international traffic in arms regulations itar. If the product has dualuse or commercial application it is controlled under the export administration regulations ear and enforced by the u. Sharing proprietary, confidential or otherwise controlled information, source code, or technology with foreign nationals located in. We make itar compliance easy avoid spending hundreds of hours wading through government regulations or wasting budget on overpriced consultants. In other simpler words, to be itar compliant, a company usml supplier needs to register with ddtc and know what is required of them to be in compliance with the itar and self certify that they possess this knowledge.
Itar compliance requirements you need to know ftp today. Itar compliance procedure manual eples pdf book manual. Directorate of defense trade controls dtc issued license and agreement documents. Export controls and trade sanctions are the united states laws and regulations that regulate and. Itar compliance manual pdf the specific objective of this itar guide is to answer the above question by providing a for pdf ebooks about sample itar compliance manual, itar. If your company falls under these categories, the following information will help answer some of your questions as to whether you need to become itar compliant and. Office of international and interagency relations responsible officials. Delivering science and technology to protect our nation and promote world stability. The nittygritty of an export compliance manual now that we ve talked about improving compliance culture, let s move to the nittygritty. The itar compliance requirements flow down to second and third tier suppliers even if you do not export. A government agent contacts your company and asks to see a copy of your itar compliance manual.
Understanding the itarear export control regulations. An effective compliance manual can help you avoid costly fines and penalties. The elements of an effective export compliance program bis us. Penalties for itar noncompliance itar export compliance. Understanding the itar ear export control regulations regarding the release of controlled technology or technical data robert mchale, esq. Not only does your company operate more efficiently and has a sense of uniformity but when there is a government investigation about alleged conduct, having a valid itar compliance manual can reduce any adverse actions and show the investigative agency that you. The international traffic in arms regulations itar are administered and implemented by the u. The vanderbilt university export compliance manual manual is intended is to provide guidance on. We also offer an expansive library of trade compliance webinars which explore more narrowly focused areas of international trade. Download itar compliance procedure manual examples itar compliance procedure manual examples pdf view online or free download from. Itar international traffic in arms regulations itn internal transaction number ivc international visit coordinator jip joint implementation plan jsc johnson space center. You cant risk violating itar, and the best way to ensure your ongoing success is by partnering with the itar consultants at export solutions. Methods for improving ethical trade compliance of an organization jarred a. Mcvey williams mullen june2, 2014 the following is a checklistof key issuesfor companiesto consider in assessingcompliance under the international traffic in arms regulations itar.
Each eseminar is 9 hours long and offers comprehensive training that is broken down into modules agenda that can be. The international traffic in arms regulations itar control the export of. Excelerate, through, offers an array of support associated with conducting international business under the itar. Management has issued a directive to comply with the international traffic in arms regulations itar. The manual applies to the ku community, including its faculty, staff, students, affiliates, visitors, vendors and contractors. We have a free ecp whitepaper download that outlines all the. As a customer to electromech, you may receive defense articles andor technical data as defined by the international traffic in arms regulations itar in 22 cfr sections 120. Typically, this access is citizenship based with authorization being defined by the u. More than ever before, companies today need to comply with all of the u. A key element of an export compliance program is an export compliance manual. Nunnwolfowitz task force report 2 one factor that may reduce criminal penalties imposed by the government for non compliance with export laws.
International traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list usml. In conclusion, this is not a guide 100% itar compliance. Checklist of complianceissues underthe internationaltraffic in arms regulations by. Most large defense contractors require itar compliance from. The itar itself only discusses the export of information related to the u. Knowledge of corporate internal controls that have been established and implemented to ensure compliance with the aeca and itar. The manual applies to the ku community, including its faculty, staff, students.
When youre finished well give you recommendations based on your answers as well as next steps for developing your program. Importance valid itar compliance manual watson lawyers. Cvg strategy itar export compliance program covers 5 major federal regulatory entities, the manual is 100 pages of policy and procedures with 42 forms. Checklist of compliance issues under the international traffic in arms regulations by. The defense export control and compliance deccs licensing application has been updated to reflect the changes outlined in the regulation entitled international traffic in arms regulations. Take the first steps to secure your business and prevent unnecessary headaches so you and your employees can focus on your business. International traffic in arms regulations itar when storing your data in aws govcloud us regions. Export control compliance manual cornell research services. Though itar compliance can be difficult to consistently implement and maintain, it is a crucial requirement for the successful, longterm exportation of defense articles. Download our itar compliance checklist for a breakdown of all the essential steps to achieving and maintaining itar compliance. Part 4 an overview of international traffic in arms regulations itar and export. Knowledge and understanding of when and how the aeca and itar affect the company with itar controlled itemstechnical data. The bis does not require a compliance manual, but it is best to include in your manual information and required procedures for the ear, ofac and cfius in addition to the itar.
This explanation does not constitute legal advice and is not for attribution. Exportimport compliance manual flow the procedures down to each group and have them update their. Export compliance program updates itar compliance solutions. Information for employers about citizenship status. Export control operations manual responsible office. It provides processes and best practices for properly and. This guide will provide you with an overview of what itar is and how it is intended to work, as well as some important considerations to make to guarantee that your organization can maintain full compliance. Export controls compliance manual research compliance rice. Munitions list usml compliance with this strict set of regulations is vital because it helps to ensure defense technology and related technical data does not fall into the hands of. International traffic in arms regulations itar is a set of u. Export management compliance program emcp automated export system compliance aes conflict mineral compliance. Download the information to a secure server and delete the email from your laptop.
Sensitive information deemed critical to the defense of the nation is subject to strict controls over its movement, use, and storage. T he objective of itar compliance is to establish executable policies and procedures that will allow your company to successfully manage itar controlled data. Itar compliance itar compliant ftp solution ftp today. Download services brochure pdf evolutions in business compliance support fees. Government regulations, from export administration regulations ear, to the international traffic in arms regulations itar and office of foreign asset controls.
Not only does your company operate more efficiently and has a sense of uniformity but when there is a government investigation about alleged conduct, having a valid itar compliance manual can reduce any adverse actions and show the investigative agency that you have a mitigation factor that may warrant leniency. A template for an itar perspective and print online pdf submit itar manual example. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. State department announces another major itar enforcement. Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be itar compliant. Export control compliance manual louisiana state university. Export compliance training institute comprehensive training. One of the best ways to mitigate risk, and stay at the tip of the spear, is to make absolute your export compliance program is up to date at least once a year. Use this comprehensive checklist to conduct annual compliance audits and detect itar non compliance based on export clearance requirements, itar controlled technical data, use of itar exemptions, and more. Risk mitigation is the name of the game when it comes to export compliance. Export compliance training institute comprehensive. Itar compliance in the cloud focuses on ensuring that information considered technical data is not inadvertently distributed to foreign persons or foreign nations.
Government regulations that requires all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data to be itar compliant. Identification, receipt and tracking of itar controlled itemstechnical data methodology used, specifically tailored to corporate structure, organization, and. Sample export compliance manual itar export compliance. What is an itar compliance program and why do you need one. G iven the increased oversight of import and export companies, the federal government is investigating both large and small companies for strict enforcement of the regulations. Training has provided employees with the knowledge and understanding of when and how the itar affect the company with itar controlled itemstechnical data. Itar compliance ftp solution streamline your collaboration, communication, and stay itar compliant. Export compliance doesnt have to be expensive, time consuming, or hard.
Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be. Itar compliance is focused on ensuring this technical data is not inadvertently distributed to foreign persons or foreign nations. What we found is that our customers take full spectrum advantage of this array based on our experience, efficiency and support in successfully executing international business. It does not purport to address all relevant trade compliance issues itar regulations 120 that may apply to a companys exporting activities. On april 25, 2018 the directorate of defense trade controls ddtc announced another major enforcement case for violations of the international traffic in arms regulations itar. Nov 05, 2014 after you register your company with ddtc see last weeks advisory, ddtc strongly advises you to implement an itar compliance program. Missile defense agency faithfully stamps all itar controlled data. The cornell university export control compliance manual addresses obligations set forth by various u. Australian best practice guide for the approved community. Compliancecommercial and military compliance support. Manufacturers, exporters and distributors of defense and defense related articles must demonstrate and document an international traffic in arms regulations itar compliance program. Australian guide to export controls and best practices.
In order for data to be subject to itar, an it workload or type of data has to be deemed an export according to the us munitions list usml. Itar compliance, itar regulations, and export licensing are just a few of the topics covered on by excelerate, inc. Download your complete itar compliance manual and training program today. Lcs can work with you to develop a customized compliance program.
The international traffic in arms regulations itar is a set of u. Export control compliance manual northeastern university. With the rigorous standards and regulations government agencies need to adhere to, its important for them to use a file sharing solution that will keep their costs down, efficient, collaborative, and ultimately secure. Department of state, directorate of defense trade controls ddtc, in conjunction with the. Compliance with the international traffic in arms regulations itar is both necessary and worthwhile to include an itar compliance program andor an itar compliance manual.
As a customer to electromech, you may receive defense articles andor technical data as defined. This manual is designed to assist the university community in. You will find that cvg strategys itar consulting is different than many other consultants itar consulting services. The sample export compliance manual published by originally.
To understand ddtcs concern about itar compliance programs, you first have to take a step back and look at what the itar is intended to accomplish. What is itar compliance and who needs to get it speak with our awesome it experts now itar is the control for the export and import of defenserelated articles and services found on the united states munitions list usml. Most large defense contractors require itar compliance from their suppliers before contracts are signed. Itar violations can be harmful to the national security and foreign policy of the u. Nothing under the itar or the ear requires or allows an employer to limit jobs to u. In the past four years, itar certification and compliance violations are becoming more commonplace in the news and headlines. Mcvey williams mullen june 2, 2014 the following is a checklist of key issues for companies to consider in assessing compliance under the international traffic in arms regulations itar.
The department of state the department proposes to amend the international traffic in arms regulations itar to revise categories i firearms, close assault weapons and combat shotguns, ii guns and armament and iii ammunition and ordnance of the. However, the itar or the ear may require your company to obtain authorization if. Fishman in an increasingly complicated and transnational business world, there is now greater importance than ever before placed on the ability of the export compliance regime to act in a positive ethical manner. In the widelycited case in re caremark international derivative litigation,4 which involved the settlement of shareholder claims against individual board members for failure. As a responsible us manufacturer or exporter you must ensure your company is compliant with the ear. Export compliance manual and verification export compliance manual rev. Ccl by way of the alphabetized index available for download here.
Itar noncompliance brings with it severe criminal and civil penalties that can end an export business. What constitutes a defense service, product, data, et. Scope and objectives of kus export compliance manual this export compliance manual manual and the policies and procedures contained herein, are designed to ensure that ku complies fully with all applicable u. Every companys management wants to have complete confidence in its trade compliance effort with respect to the international traffic in arms regulations itar and export administration regulations ear.
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