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Getting and staying ITAR compliant with ISO Pros
Know your business, its obligations, and areas of risk. Whether you are engaging in the production, sale, temporary acquisition or brokering of military products (including technological data), or the supply of ITAR-controlled security facilities (see the U.S. Munitions List), you ought to learn what the ITAR demands of you. These will include (1) registration, (2) record-keeping needed by 22 CFR § 122.5, and (3) acquiring licenses or other permits prior to sale, temporary import, or brokering (see licenses and agreements).
We help you to create and enforce a plan of compliance
Implementation with the Office of Defense Trade Controls actively urges those participating with security trading to develop and implement an ITAR / export compliance plan. They depend on everyone working with USML products to help them secure important technology for our country.
You ought to consider how the organization works to assess the danger areas before developing a compliance plan. The existence of articles of security or electronic details increases the chance of an inadvertent violation. Most companies who don’t participate in the production, selling, or brokering tend to develop enforcement plans to reduce the possibility of these breaches.
In general, a good scheme:
- has clear documentation in writing
- modified for a specific business market
- receives regular reviews and updated periodically
- totally supported by top management
The FAQs further specify that, with the degree that exporters and/or foreign entities are in proper faith adopting the frameworks proposed which have been revised by the law of 2015 on the procurement by defense services by U.S. persons overseas, which, amongst other items, included an exception for a U.S. contractor of any foreign person under certain circumstances, DDTC would generally consider the delivery for defense services by the U.S.
For more clarity on, inter alia, the specific information needed for the authorization request and the conditions to be fulfilled before the authorization request is sent, please see the full text of the FAQs.
Contact us to take advantage today and protect your business
The effect of U.S. export control changes on the security sector should be optimistic. The re-allocation of a number of U.S. military articles from regulating the International Traffic in Arms Regulations (ITAR) to managing the Export Management Regulations (EAR) would greatly change the way a business conducts its main contracts. It will also take away the problems with ITAR taint which prohibits other business initiatives from going forward. All companies who recognize the effect of U.S. legislation, and seek to efficiently handle the transfer of U.S. products and technologies from ITAR to EAR, expect to gain rewards from project cost savings, shortened lead times and expanded market prospects as a consequence of regulatory adjustments.
A transition for the better
More than half of the ITAR has now been updated as a consequence of U.S. legislation to establish a collection of exclusively military articles that tend to demand strict restrictions owing to their particular technical capabilities. Less important military products were withdrawn from the US Munition List (USML) of the ITAR and transferred to the Commerce Control List (CCL), which regulates both dual-use and military equipment.
A main benefit of the EAR is the EAR permits business to self-assess licensing criteria. The EAR is organized in a way less vague than the ITAR in terms of describing what’s being monitored and how restrictions are being implemented. Regulated products are defined in-depth on the CCL, and the licensing conditions for each object are specifically illustrated. Businesses who recognize the EAR will decide if they need a license to re-export or retransfer it. To stop errors that may end in inadvertent breaches, a rigorous implementation plan will, of course, be enforced.
Give ISO Pros a call today to help your organization to not only become ITAR compliant but to stay compliant and take advantage of the benefits available to be ITAR compliant.