End The Confusion About ITAR

Are you confused about DDTC Registration, does it apply to you? Not sure if an export requires U.S. Government authorization? Don’t know if your company manufactures parts that are “ITAR” or “EAR” Controlled? Does your compliance program cover the basics? Contact Aerospace Exports Incorporated at: Info@aerospaceexports.com Subscribe to AEI’s mailing list * indicates required Email […]

Aerospace Exports Incorporated

Export Compliance Program

Export Compliance Program Overview 1.Management Commitment Effective management support includes the provision of adequate resources to the compliance staff and support for compliance personnel’s authority within an organization. 2. Risk Assessment While there is no “one-size-fits all” risk assessment, the exercise should generally consist of a holistic review of the organization from top-to-bottom and assess […]

DOJ Publishes Guidance on Evaluating Corporate Compliance Programs

The DOJ Criminal Division Announces Publication of Guidance on Evaluating Corporate Compliance Programs Note these three questions extracted from the guidance document: 1. “Is the corporation’s compliance program well designed?“ 2. “Is the program being applied earnestly and in good faith?“ In other words, is the program being implemented effectively? 3. “Does the corporation’s compliance […]

Aerospace Exports Incorporated

U.S. Person, yes or no?

Answering your questions… “If my employee is not a U.S. citizen, does not have a Green Card but does have an EAD (Employement Authorization Document), are they considered a U.S. Person per the ITAR?” The answer is no.  Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name

Technical Data, yes or no?

NOTE: These are used by AEI as internal tools only, they are not enumerated in the ITAR or EAR. If the drawing is of an item that is controlled by the ITAR, it may be considered technical data if it: Contains quantitative information; Was generated by independent R&D for military application; Was generated under a […]

Export Compliance Programs – Internal Audits

Export Compliance Program The BIS has posted great introduction videos. Check them out here at the Online Training Room: https://www.bis.doc.gov/index.php/compliance-a-training/export-administration-regulations-training/online-training-room Check out all of the videos, but organizations should take note to the video on the subject of the importance of organizations creating and maintaining an Export Compliance Program (ECP). The video emphasizes the eight […]

Best Practice: ITAR License Application

When preparing an application for a license, a best practice is to include more than one freight forwarder. The ITAR suggests that applicants should list all freight forwarders who MAY be involved with shipments under the license to ensure that the list is complete and to avoid the need for amendments after the listed has […]

Aerospace Exports Incorporated

Don’t Ignore Regulations

So this week we’re learning that the Commerce Department can start using new tools, such as undercover agents and wiretaps, to conduct investigations. This news should worry all those leaders in companies who continue to ignore the EAR & ITAR. Who is making your compliance decisions? What decisions need to be made in order to […]