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” […]

Aerospace Exports Incorporated

RWAs are not CJs

Recently a client asked if they can accept a RWA from the DDTC as a CJ. In investigating the background the client had submitted a license application to the DDTC, the application was RWA’d as subject to the DoC (600 Series). The client wanted to utilize the RWA as a official notification to it’s customers […]

Aerospace Exports Incorporated

$8,000,000 in Civil Penalties

What happens when an organization does not properly classify an item To all those organizations that do not accurately classify items or take little or no care when selling domestically, the latest charging letter issued from the Office of Defense Trade Controls should get your attention: See the DDTC Charging Letter The Department of State […]

Aerospace Exports Incorporated

Today’s Brief

Purpose: The purpose of this of these subject briefs is to provide the aerospace supplier a clear path to understanding the U.S. Export Control Regulations.   Today’s Brief: What or who is U.S. Person? Lets begin with the definitions according to the ITAR starting with a person then a U.S. person:   § 120.14  Person Person means […]

Aerospace Exports Incorporated

Protecting Technical Data

Is being a victim of a cyber attack an ITAR violation? With all the reported stories of foreign attacks on U.S. based companies in which technical data has been reported stolen, should the victim submit a Voluntary Disclosure? Cloud computing is very popular, it is commonly used by both service and commodity providers but the […]