Read 127.1(b)(3) about manufacturers… §127.1 Violations. (a) Without first obtaining the required license or other written approval from the Directorate of Defense Trade Controls, it is unlawful: (1) To export or attempt to export from the United States any defense article or technical data or to furnish or attempt to furnish any defense service for which […]
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Using ISO 19600:2014 “Compliance management systems guidelines”
Integrating ITAR and EAR requirements into an AS9100 Quality Management System can be daunting. The image posted above is a broad overview of the identification step. Note that organizations should use their functional experts to perform the evaluations. Good Luck! Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name
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 […]
The Aerospace ITAR Supplier Registry
Why the aerospace industry needs to validate supply chain compliance to the ITAR and EAR. AEI Aerospace Supplier Registry Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name
OFAC Penalties/Settlements 2010-2014 YTD
Here are the totals since 2010. OFAC Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name
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 […]
How Did You Start Working In Export Control?
Share your story, how did you end up working compliance? Did you start out as a Trade Attorney, were you an Engineer, Logistics, Security, or QA? Also, tell us in what department you reside and is trade compliance just one of many responsibilities? It is interesting to see where companies place the responsibility of compliance, […]
Why Private Conformance Audits Better Serve the CEO
Tactical Use of Process Systems Assessments Why Private Conformance Audits Better Serve the CEO For nearly twenty years ISO Registrars have been assessing organizations to Quality Management System Standards. The focus of the ISO Quality System Standard is Customer Satisfaction, meeting the customer’s requirements. These are solid goals and when embraced can aid in the […]
$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 […]
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 […]
Attention ITAR Cheats
To all those who thumb their nose at compliance, to those who say “I have a way around it..” we hope the DoJ slams you. Recently we received a call to assist an organization in obtaining DDTC Registration and then subsequently prepare a DSP-5 Application. When the client was told that registration would not granted within […]
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 […]