Who needs to comply with ITAR?
Any individual or company that deals with defense-related articles and services on the USML needs to comply with ITAR regulations. This includes manufacturers, exporters, brokers, and even universities and research institutions that work on defense-related projects. Under ITAR 22 CFR §122.1, parties that manufacture, export or temporarily import “defense articles” or furnish “defense services” are required to register with the Directorate of Defense Trade Controls (DDTC) within the State Department. It is important to note that even parties that engage solely in domestic manufacturing of defense articles that do not engage in any exporting or importing are required to register. If your organization is AS9100 certified or pursuing that certification, there’s a good chance ITAR applies to you.
What are the requirements for ITAR compliance?
To comply with ITAR regulations, you need to:
Register with the Directorate of Defense Trade Controls (DDTC): The DDTC is the agency responsible for enforcing ITAR regulations. To register with the DDTC, you need to complete the necessary forms and provide detailed information about your company and the defense-related articles and services you deal with.
Implement an ITAR Compliance Program: An ITAR Compliance Program is a set of policies and procedures that ensure that your company complies with ITAR regulations. This includes measures such as training employees on ITAR requirements, conducting regular audits of your export control practices, and maintaining accurate records of your transactions.
Obtain an ITAR License: If you plan to export defense-related articles and services on the USML, you will need to obtain an ITAR license from the DDTC. To obtain a license, you will need to demonstrate that your export will not harm national security and that you have a robust ITAR Compliance Program in place.
Why is ITAR compliance important?
Complying with ITAR regulations is critical for national security and your company’s reputation. By ensuring that defense-related technology does not fall into the wrong hands, you help protect our country from potential threats. Failure to comply with ITAR regulations can result in severe penalties, including fines, imprisonment, and revocation of export licenses. It can also damage your company’s reputation and make it difficult to do business with government agencies and contractors. The classification and compliance process has only become more complex under Export Control Reform (ECR) as well as various new regulations and interpretations.
How Core can help you achieve ITAR compliance?
Core Business Solutions specializes in helping companies achieve ITAR compliance. Our experts can help you:
- Conduct an ITAR Compliance Audit: Our team will review your current export control practices and identify areas that need improvement to achieve ITAR compliance.
- Develop an ITAR Compliance Program: We will work with you to develop a comprehensive ITAR Compliance Program that meets the specific needs of your company.
- Train Your Employees: We offer ITAR compliance training for your employees to ensure that they understand their responsibilities and obligations under ITAR regulations.
- Register with the DDTC within the State Department. We can assist you with this process as well.
- Annual compliance and registration update services are also available.
ITAR is complex but our ITAR consultants understand the details and will create a custom program to fit your company. We specialize in helping small businesses with ITAR compliance.