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 […]

Aerospace Exports Incorporated

Seeking PT Contract Sales and Consultants

Sales: Aerospace Exports Incorporated is seeking part time contract sales person. The position requires knowledge of the aerospace industry, LInkedIN and other social media. The position will be 1099 subcontract and will pay a negotiated commission/rate. Consultant: Aerospace Exports Incorporated is seeking part time consultant to service AEI clients via phone and email. No on-site […]

Aerospace Exports Incorporated

Quiz of the Week

What records must the Registrant keep available at all times? Must maintain records concerning the manufacture, acquisition and disposition (to include copies of all documentation on exports using exemptions and applications and licenses and their related documentation), of defense articles; of technical data; the provision of defense services; brokering activities; and information on political contributions, […]

Aerospace Exports Incorporated

Quiz of The Week

Empowered Officials, Are You Qualified Under §120.25? Attention Empowered Officials, would you like to test your knowledge? Send us an email with your answers to this short quiz and we will contact you with your results. We will also include a complimentary presentation: EO’s Guide To Compliance 1. Define a U.S. person: 2. Does “Directly Employed” include […]

Aerospace Exports Incorporated

DDTC Registration is NOT automatic compliance to the ITAR

Just yesterday I was asked “As long as we register with the DDTC we can self-declare as ITAR compliant… right?” My reply is always a big “NO”. I also include a warning… any organization that self-declares compliance based solely on DDTC Registration and then advertises as such, may receive some un-requested attention: http://www.exportlawblog.com/archives/4467 I thoroughly appreciate the […]

Aerospace Exports Incorporated

New NAS Standard Announced

AIA’s National Aerospace Standards (NAS) has released TCS001: Document marking, storage, and electronic transmission of technical data, and provides guidance on the processes and best practices necessary for a company to manage U.S. EAR-controlled technology exports, including technical data, in compliance with the Export Administration Regulations (EAR). A member of the AEI team was pleased to participate […]

Aerospace Exports Incorporated

Quality System Verification and Validation for ITAR Processes

AS9100 requires that organizations identify applicable regulatory requirements however most Quality Management Systems DO NOT contain processes to verify and validate actions performed by Empowered Officials. Fact: Empowered Officials must certify that information provided on applications is accurate. Problem Scenario An Empowered Official is tasked with applying for a DSP-5 for a Foreign Person “working” […]