This manual is an example and is intended only as a guide. What is an itar compliance program and why do you need one. Export control laws and regulations, to identify key export compliance issues related to research. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. What constitutes a defense service, product, data, et. Methods for improving ethical trade compliance of an organization jarred a. 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. It does not purport to address all relevant trade compliance issues itar regulations 120 that may apply to a companys exporting activities. Export compliance training institute comprehensive training. If the product has dualuse or commercial application it is controlled under the export administration regulations ear and enforced by the u. Purpose the purpose of this export compliance manual is to provide the cmu community with. The itar frequently asked questions guide contains answers to over 70 questions most often asked by exporters who are regulated by the. The nittygritty of an export compliance manual now that we ve talked about improving compliance culture, let s move to the nittygritty. Download itar compliance procedure manual examples itar compliance procedure manual examples pdf view online or free download from.
There are a number of issues to consider when exporting, but the basic export compliance procedure for a transaction involving autodesk or autodesk media and entertainment products or technology is as follows. This publication of the international traffic in arms regulations itar is intended to be a convenient reference guide for the reader. Export compliance essentials for sales and marketing export. Obtain the eccn of the product or technology and determine which export restrictions apply. Take the first steps to secure your business and prevent unnecessary headaches so you and your employees can focus on your business. Export control operations manual responsible office. International traffic in arms regulations wikipedia. Let me set the stage for this series of tutorials on international traffic in arms regulations or itar.
Office of international and interagency relations responsible officials. 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. Itar compliance is focused on ensuring this technical data is not inadvertently distributed to foreign persons or foreign nations. We make itar compliance easy avoid spending hundreds of hours wading through government regulations or wasting budget on overpriced consultants. The expectation is that you are educated and trained in itar regulations. Mcvey williams mullen june2, 2014 the following is a checklistof key issuesfor companiesto consider in assessingcompliance under the international traffic in arms regulations itar. Technology is a critical part of the does mission and requires special consideration in identifying and protecting sensitive technologies including intellectual property and pending patents. Global trade expertise hot topicsnews a guide to selected u.
Identification, receipt and tracking of itar controlled itemstechnical data methodology used, specifically tailored to corporate structure, organization, and. Itar compliance policy builder this page is a quick start tool to help launch your itar policy program. 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. Download your complete itar compliance manual and training program today. Itar compliance rules are complex, and it is important for organizations in the defense industryand defense manufacturers supply chain partnersto understand if and how itar compliance requirements apply to them.
As a customer to electromech, you may receive defense articles andor technical data as defined. 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. Implementing archiving tools can be challenging due to limited personnel, it resources, and budget constraints. Comprehensive operational compliance programs include manuals that articulate. Export compliance manual and verification export compliance manual rev.
The elements of an effective export compliance program bis us. When youre finished well give you recommendations based on your answers as well as next steps for developing your program. This operations manual provides implementing instructions for nasas export control policies and processes. In conclusion, this is not a guide 100% itar compliance. Overall, it is important to understand that registering with the ddtc to sell your products or services in the itar industry is not enough. Management has issued a directive to comply with 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. Hugh compliance, to gain access to the study guide and test for the annual update itarear qualification. Export compliance requirements under the international traffic in arms regulations itar and the export administration regulations ear create burdens for salespeople and compliance professionals. Export control compliance manual louisiana state university. Export control compliance manual northeastern university. Ccl by way of the alphabetized index available for download here. As a responsible us manufacturer or exporter you must ensure your company is compliant with the ear. This explanation does not constitute legal advice and is not for attribution.
This manual is designed to assist the university community in. Sample export compliance manual itar export compliance. In spite of its name, itar compliance isnt just for arms dealers. The vanderbilt university export compliance manual manual is intended is to provide guidance on u. Pat crow wpc to be in full compliance with all applicable laws and regulations. Excelerate, through, offers an array of support associated with conducting international business under the itar. Missile defense agency faithfully stamps all itar controlled data. 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.
Important elements of effective manuals and programs include. You will find that cvg strategys itar consulting is different than many other consultants itar consulting services. Download our itar compliance checklist for a breakdown of all the essential steps to achieving and maintaining itar compliance. Importance valid itar compliance manual watson lawyers. Compliance with any questions on export control, licensing, shipping, etc. Department of state, directorate of defense trade controls ddtc. Control act aeca and the international traffic in arms regulations itar. Understanding the itar ear export control regulations regarding the release of controlled technology or technical data robert mchale, esq. Understanding the itarear export control regulations. The manual applies to the ku community, including its faculty, staff, students. Export compliance doesnt have to be expensive, time consuming, or hard. Comprehensive operational compliance programs include manuals that articulate the processes to be followed in implementing the company program. 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.
We also offer an expansive library of trade compliance webinars which explore more narrowly focused areas of international trade. 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. Barracuda for the federal government security and data. The sample export compliance manual published by originally. We have a free ecp whitepaper download that outlines all the.
Department through its international traffic in arms regulations itar and the arms export control act aeca, and the treasury department through the office of foreign assets control ofac administer the export control laws and trade sanctions. The international traffic in arms regulations itar control the export of. Aug 01, 2014 itar compliance and interactions with customers, suppliers and visitors 1. Cvg strategy itar export compliance program covers 5 major federal regulatory entities, the manual is 100 pages of policy and procedures with 42 forms. Itar compliance and interactions with customers, suppliers. Its very easy to become frustrated with export rules and regulations because they are illogical and often do not make sense. Jul 15, 2019 what does the itar mean for my company. The commerce department administers the commerce contro l list ccl and the state department. Itar compliance procedure manual eples pdf book manual free. The international traffic in arms regulations itar is a set of u. You cant risk violating itar, and the best way to ensure your ongoing success is by partnering with the itar consultants at export solutions. Checklist of complianceissues underthe internationaltraffic in arms regulations by. Training has provided employees with the knowledge and understanding of when and how the itar affect the company with itar controlled itemstechnical data. 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.
The official versions of the regulations contained herein are set forth in the annual printings of title 22 of the code of federal regulations cfr, as amended in the federal register fr. 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. International traffic in arms regulations itar is a united states regulatory regime to restrict. An itar compliance program is established based on a top level set of guidelines provided by dtc and industry accepted standards for compliance execution.
Also, the consolidated screening list is available in a downloadable file that consolidates export. Ear compliance compliance with the export administration regulations ear is a requirement for all us companies. The itar itself only discusses the export of information related to the u. Lcs can work with you to develop a customized compliance program. Itar compliance in the cloud focuses on ensuring that information considered technical data is not inadvertently distributed to foreign persons or foreign nations. In order to meet strict mandates, as well as ediscovery and compliance requirements, federal agencies need to have a simple way to store and access all email communications.
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