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 […]

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 […]