Aerospace Exports Incorporated

ISO 9001 & AS9100 Registrar Auditors: Stop Writing Poor Nonconformance Statements, Learn to Cite the Proper Paragraph of the ITAR or EAR

Auditors who are ignorant of the regulations and then who draft poorly written NC statements can damage the credibility of the Registrar. Registrars, have your auditors ever issued similar findings: “The process of ensuring that top management shall demonstrate leadership and commitment with respect to customer focus by ensuring that the customer and applicable statutory […]

Your Baby is Ugly

No one wants to here the words, your baby is ugly. When AEI is tasked to assess a client’s compliance processes, sometimes we have to tell the client that their processes, training and personnel have a hole large enough for a violation to escape. Yes, an escape can happen at any company at any time […]

Regulatory Requirements & Policy Conflicts

Organizations should closely analyze requirements from their customers who flow down regulatory requirements such as the FAR and/or DFARS to determine if conflicts exists. In an analysis of certain Defense Federal Acquisition Regulations Supplement, I noticed what could be a conflict for those organizations who may seek to use a Voluntary Disclosure as a result […]

Aerospace Exports Incorporated

Checklist for DFARS 252.204-7012

A few weeks ago AEI held a complimentary webinar explaining the Cyber Security and Reporting DFARS 252.204-7012 clause. During the webinar we demonstrated our checklist. Since the webinar we have been swamped for requests for the checklist. If you would like your own copy, please send us an email, provide your name and company name and we […]

Aerospace Exports Incorporated

Pomona California: Woman arrested on federal charges

On Tuesday, May 23, 2017 a woman with a rented office in Pomona California was arrested on federal charges that accuse her of conspiring to procure and illegally export sensitive space communications technology to her native China. Read the full DoJ News Release here: https://www.justice.gov/usao-cdca/pr/pomona-woman-arrested-federal-charges-allege-scheme-smuggle-restricted-space How did this person acquire devices that are commonly used […]

Aerospace Exports Incorporated

The Feds can do what?

Regardless if your company is publicly or privately held, the U.S. Government by using the Federal Acquisition Regulations can require and enforce cyber controls on your company networks. Your private networks. Learn if this Federal Acquisition Regulation applies to your firm.  Contact AEI at info@aerospaceexports.com  

Aerospace Exports Incorporated

Is Your Business At Risk?

Hundreds and possibly even thousands of small businesses were or are victims of cyber crime. The ransom ranges from hundreds into the thousands dollars.  So whether you are required by the Federal Acquisition Regulations or simply want to protect your business, consider this when you think about your cyber controls: What is the chance that […]

Aerospace Exports Incorporated

Performing an Effective Gap Analysis

The is a lot a talk about the upcoming Cyber Security requirement deadline in December 2017, yes, I’m referring to NIST SP 800-171. Many organizations are scrambling to assess their compliance. Most QA Managers are doing what comes natural, they are relying on the GAP ANALYSIS in order to measure their compliance. Performing a Gap analysis […]

Aerospace Exports Incorporated

Import Compliance

A prospect was boasting that they have someone in Mexico who assists them in completing the import paperwork. The prospect didn’t understand the transactions, the applicable regulations or the documents but they were happy. What could go wrong? Can you demonstrate compliance awareness through knowledge of the Customs Regulations and Harmonized Tariff Schedule of the […]

Compliance Strategy

Failure to face the challenges of compliance will most likely result with a violation or an unintended “escape” sometime in the future. When the violation finally comes and you receive that “Letter” from the DDTC or BIS, you will experience fear and an overwhelming sense of panic. Initially the costs will start with the usual $5,000 retainer for legal […]

Compliance Deficit or Loss: An Auditor’s Tip

When assisting an organization in learning about the various export regulations such as the ITAR and EAR, we often hold “Executive Awareness” training for the leadership. Now there are some leaders who while learning about their responsibilities and all of the numerous requirements in complying with the regulations, they take immediate action: For instance some may assign […]

Aerospace Exports Incorporated

Top ten immediate actions for new DDTC Registrants

 Export Compliance Implementation Plan Immediate Actions Assure that all exports are accurately classified and the export control documents contain the proper destination control statement, this includes Bill of Lading, Airway Bill, Commercial Invoice, Packing Slip. All items (commodities, technology, and software) shall be classified in order to determine jurisdiction (ITAR OR EAR), and with specific […]

Aerospace Exports Incorporated

ITAR Compliance 101

Often larger aerospace OEMs/Primes ask us to assist or mentor a key sub-tier supplier in achieving ITAR Compliance. Once we are introduced (to the supplier) we start by having a conversation with the senior executives on what they manufacturer, number of employees etc., but inevitably during that first phone call we are asked straight-out “How […]