Aerospace Exports Incorporated

ITAR Compliance vs ISO Certification

Is ITAR compliance an on-going continual functioning system of processes or binary on or off, yes or no? Scenario: A prospective client asks for help to become “ITAR Compliant”. Our first question is what is the contractual requirement? Did the PO simply state “ITAR Compliant” or do you need to apply for a license, where […]

Aerospace Exports Incorporated

FYI… Interim final rule is effective on March 25, 2020

Interim final rule is effective on March 25, 2020 Department of State 22 CFR Part 120 [Public Notice: 10946]  RIN 1400–AE76 International Traffic in Arms Regulations: Creation of Definition of Activities That Are Not Exports, Reexports, Retransfers, or Temporary Imports; Creation of Definition of Access Information; Revisions to Definitions of Export, Reexport, Retransfer, Temporary Import, […]

Aerospace Exports Incorporated

ITAR Export Control Documents & the misrepresentation and omission of facts

§127.2   Misrepresentation and omission of facts. (a) It is unlawful to use or attempt to use any export or temporary import control document containing a false statement or misrepresenting or omitting a material fact for the purpose of exporting, transferring, reexporting, retransferring, obtaining, or furnishing any defense article, technical data, or defense service. Any false statement, […]

Aerospace Exports Incorporated

Consultants: Expand Beyond ISO Into ITAR/EAR Compliance Consulting

ISO Consulting is saturated and hourly rates are dropping. Expand your services and increase revenue through compliance consulting. In this webinar learn about the tools to expand your consulting business and increase revenue.  Learn how you can provide guidance and clarity to your customers to understand the core elements of Export compliance (ITAR and EAR) […]

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 […]

Aerospace Exports Incorporated

Supply Chain Communication and ITAR

Is there uncertainty in your communications with your customers and suppliers regarding the jurisdiction of a commodity, whether it be subject to the EAR or ITAR? Uncertainty in communication is a risk to all involved, the suppliers, customers and community. When an organization doesn’t adequately perform it’s due diligence, it puts everyone at risk.    […]

Cascading Risk

If your involved with manufacturing Defense Articles then your organization is at risk that a supplier or customer may be involved in a violation to the ITAR. It is that simple, with the growing number of companies that are not ITAR compliant the risk of an inadvertent breach of the ITAR cascades faster and faster. […]

Aerospace Exports Incorporated

ITAR Visitor Tracking Tool

The road to ITAR & EAR compliance can start with a few simple questions, Where are we now? Is our Empowered Official knowledgable in the regulations? Are our processes supporting compliance or are there opportunities for escapes?  Here’s a question that is often asked, Do we have to screen visitors?  If your organization needs a […]

Aerospace Exports Incorporated

ITAR: Mandatory Disclosures

Not all disclosures are (in the true sense of the word) voluntary. There are some ITAR Disclosures that are mandatory which could mean an additional ITAR violation if not disclosed. Be sure to read and understand if these apply to your organization: § 123.17(j) If the articles temporarily exported pursuant to paragraphs (c) and (f) through […]