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… Continue reading ITAR Compliance vs ISO Certification
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,… Continue reading FYI… Interim final rule is effective on March 25, 2020
§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,… Continue reading ITAR Export Control Documents & the misrepresentation and omission of facts
Annual report is near, do you have your records in order? Do you even know what the ITAR and EAR requires for Semi and/or Annual Reporting? If you’re unsure, drop us an email and we’ll send you a reporting checklist for both the ITAR & EAR. Subscribe to AEI’s mailing list * indicates required… Continue reading Happy New Year… It’s Time for the EAR & ITAR Annual Reports
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)… Continue reading Consultants: Expand Beyond ISO Into ITAR/EAR Compliance Consulting
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… Continue reading Best Practice: ITAR License Application
What is going to be your trigger to finally decide on becoming compliant with the Arms Export Control Act? Is it that you learned the definition of a defense article as defined in Part 120 Purpose and Definitions, or That you understand that as a manufacturer of defense articles you must register with the DDTC… Continue reading A Trigger, Becoming ITAR Compliant
Are your processes operator controllable? Does your compliance team know what is expected of them? Remember, Knowing is not Doing. Compliance requires both Knowing and Doing. Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name
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… Continue reading Don’t Ignore Regulations
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. … Continue reading Supply Chain Communication and ITAR
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.… Continue reading Cascading Risk
Getting started is about taking that first step. Nothing happens until you begin. If you don’t know how to get started, AEI can guide you through the things you need to do RIGHT. With our decades of aerospace and ITAR expertise, we can help you avoid the costly mistakes often made during implementation. Myth:… Continue reading Still questioning whether you need to be ITAR ready?
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… Continue reading ITAR Visitor Tracking Tool
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… Continue reading ITAR: Mandatory Disclosures
Practitioners of the ITAR often experience frustration when customers can’t or will not provide an accurate classification of controlled data being passed on (i.e. a drawing of a part or assembly). For example we have all received that all to common warning: WARNING – This document contains technical data whose export is restricted by the… Continue reading We’re from the government and we’re here to help.