ITAR Compliance
The objective of ITAR compliance is to establish executable policies and procedures that will allow
your company to successfully manage ITAR controlled data. Typically, this access is citizenship
based with authorization being defined by the U.S. Directorate of Defense Trade Controls (DTC)
issued license and agreement documents. The penalties for not securing ITAR controlled data can
be significant and have lasting effects on business with the United States.
Unlike other programs, like ISO, there is no “certification” process associated with ITAR
compliance. An ITAR Compliance Program is established based on a top level set of guidelines
provided by DTC and industry accepted standards for compliance execution. There will be no
governing body reviewing and certifying your company's compliance program by instead a s
specific set of compliance elements must be met to be considered a viable compliance program
by DTC. These include:
•
A documented corporate commitment to ITAR compliance by senior management.
•
Methodology for identification, receipt, and tracking of controlled items and technical
data.
•
A procedure for screening customers , carriers, and countries.
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Description and procedures for maintaining proper ITAR records.
•
How internal monitoring and audits will be performed to ensure the integrity of
compliance.
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An explanation and process for educating, training and guiding all employees related to
the ITAR.
•
Procedures for notification of potential violations to the ITAR.
In addition to and as part of ITAR compliance your company may need to be registered
with DTC. If you are a foreign company, you may need to register as a “Foreign Broker”.
This depends on the company’s role with the end user.
Compliance Services
Excelerate will provide the following services as part of establishing your ITAR Export
Compliance:
•
Registration: Evaluation and support, as required, to become registered with DTC.
•
Technology Control Plan (TCP): Establish a TCP for your company that satisfies
compliance elements required by the DTC.
•
ITAR Training: Provide ITAR training to the compliance team, employees, and
management on how to work in association with the ITAR.
•
Audit: Establish an Audit Plan for annual execution to ensure compliance is
maintained.
•
Review: Review any current license and agreement documents to identify any
concerns and assist the compliance team in managing existing efforts.
Excelerate has a successful record of establishing and monitoring ITAR Compliance
Programs for many customers. We suggest checking out our Starter Bundle for
quick and easy implementation of your ITAR Compliance Program.