End The Confusion About ITAR

Are you confused about DDTC Registration, does it apply to you? Not sure if an export requires U.S. Government authorization? Don’t know if your company manufactures parts that are “ITAR” or “EAR” Controlled? Does your compliance program cover the basics? Contact Aerospace Exports Incorporated at: Info@aerospaceexports.com Subscribe to AEI’s mailing list * indicates required Email […]

Aerospace Exports Incorporated

Export Compliance Program

Export Compliance Program Overview 1.Management Commitment Effective management support includes the provision of adequate resources to the compliance staff and support for compliance personnel’s authority within an organization. 2. Risk Assessment While there is no “one-size-fits all” risk assessment, the exercise should generally consist of a holistic review of the organization from top-to-bottom and assess […]

DOJ Publishes Guidance on Evaluating Corporate Compliance Programs

The DOJ Criminal Division Announces Publication of Guidance on Evaluating Corporate Compliance Programs Note these three questions extracted from the guidance document: 1. “Is the corporation’s compliance program well designed?“ 2. “Is the program being applied earnestly and in good faith?“ In other words, is the program being implemented effectively? 3. “Does the corporation’s compliance […]

Aerospace Exports Incorporated

U.S. Person, yes or no?

Answering your questions… “If my employee is not a U.S. citizen, does not have a Green Card but does have an EAD (Employement Authorization Document), are they considered a U.S. Person per the ITAR?” The answer is no.  Subscribe to AEI’s mailing list * indicates required Email Address * First Name Last Name

Technical Data, yes or no?

NOTE: These are used by AEI as internal tools only, they are not enumerated in the ITAR or EAR. If the drawing is of an item that is controlled by the ITAR, it may be considered technical data if it: Contains quantitative information; Was generated by independent R&D for military application; Was generated under a […]

Export Compliance Programs – Internal Audits

Export Compliance Program The BIS has posted great introduction videos. Check them out here at the Online Training Room: https://www.bis.doc.gov/index.php/compliance-a-training/export-administration-regulations-training/online-training-room Check out all of the videos, but organizations should take note to the video on the subject of the importance of organizations creating and maintaining an Export Compliance Program (ECP). The video emphasizes the eight […]

Not DDTC Registered and you state that you ARE ITAR compliant?

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 […]

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

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 […]