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 […]

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 […]