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 (i) of this section are not returned to the United States, a detailed report must be submitted to the Office of Defense Trade Controls Compliance in accordance with the requirements of §127.12(c)(2) of this subchapter.
- § 126.1(e)(2) Duty to notify. Any person who knows or has reason to know of a proposed, final, or actual sale, export, transfer, reexport, or retransfer of articles, services, or data as described in paragraph (e)(1) of this section must immediately inform the Directorate of Defense Trade Controls. Such notifications should be submitted to the Office of Defense Trade Controls Compliance, Directorate of Defense Trade Controls.
- § 130.9 Obligation to Furnish Information to the Directorate of Defense Trade Controls