Thank you for the opportunity to present this proposal to assist you in achieving compliance in accordance with the International Traffic In Arms Regulations and the Export Administration Regulations.
Engaging in international trade is a never-ending challenge and compliance to the requirements imposed by the various U.S. Government Agencies can be daunting. Here at AEI we focus on the aerospace & defense supply chain. Because of our extensive ISO and Aerospace experience we are highly confident that we can assist you in developing a compliant and effective export control program. We understand that embedding the ITAR/EAR requirements directly into your existing management system is the most cost effective method to assure continual compliance.
As you may be aware the Department of State’s Directorate of Defense Trade Controls (DDTC) administers defense-related export controls under the authority of the Arms Export Control Act. Controlled items are listed in the United States Munitions List (USML) within the International Traffic In Arms Regulations (ITAR). The Department of Commerce’s Bureau of Industry and Security (BIS) administers all export controls (Export Administration Regulations) not administered by another U.S. government agency. Classifying controlled items is crucial to assure compliance.
Simply being DDTC Registered does not project or declare “compliance”, in fact the DDTC registered organization must appoint an Empowered Official who according to §120.25(a)(3) “Understands the provisions and requirements of the various export control statutes and regulations, and the criminal liability, civil liability and administrative penalties for violating the Arms Export Control Act and the International Traffic in Arms Regulations”.
If you have any questions regarding this proposal, please contact me at your earliest opportunity. We look forward to hearing from you.
Aerospace Exports Incorporated
1. DDTC REGISTRATION/LICENSE APPLICATION:
Assist with DECCS System Registration
Assist with DDTC Registration Application preparation and submittal through the DECCS (DDTC Registration Fees are paid by client directly to the Department of State).
2. TECHNOLOGY CONTROL PLAN/PROCEDURES:
Provide the following export control policies and procedures:
Technology Control Plan
Corporate Policy Statement
Customer End-Use, End-User Questionnaire
ITAR/EAR/FTR Control Record Keeping
Denied Party Screening, Suspect Violations Processing, License & Application Processing
Employee on-boarding requirements
Employee Compliance Statement
Purchase Order Clauses
3. COMPLIANCE OFFICER/EMPOWERED OFFICIAL TRAINING:
Controlled Item Jurisdictional Analysis and Classification
Part and Drawing Marking
Day To Day Operations:
Executive Management & Administration
Empowered Officials, Compliance Officers
Various USG Agencies, why compliance is important
Employee Training and Screening
Operations, Quality Assurance, Customer Service, Engineering, Shipping and Receiving
The Details of Each Regulation Covered Include:
|International Traffic In Arms Regulations||Export Administration Regulations|
|General overview||Subject to the EAR|
|Basic steps to compliance||Public domain|
|ITAR structure and definitions||De Minimis|
|The DDTC organization||General prohibitions|
|Relation to regulations of other agencies||Country chart|
|What and Whom Does the ITAR Regulate||Responsible parties|
|What does the ITAR regulate and not regulate||Classifications|
|Persons, parties, and destinations||Licenses and Applications|
|Transactions||How to apply|
|Defense Articles||Supplementary documents|
|Commodity jurisdiction requests||Bill of lading|
|Empowered officials||Destination control statement|
|Screening||Exceptions and Post Shipment Responsibilities|
|Export contracts||License exceptions|
|Export Authorizations||Audits and compliance|
|Import/Export licenses, certificates and applications||Retention of records|
|Temporary import or exports|
4. General Employee Introduction to ITAR (30 Min session). All employees not attending the advanced class must attend this introduction course:
Introduction to Defense Articles and Dual-Use Items:
What is an Export
Violations and Penalties
Initial Fee: $3,200, with an additional on-going monthly support agreement, the monthly fee is $375.
These “virtual off-site” services include:
EXPORT CONTROL & DFARS SUPPORT SERVICES
Customer/Order Screening – Perform screen of export transaction parties against U.S. Government restricted party lists to reduce the risk of conducting government prohibited export transactions.
Export Jurisdiction and Classification Determinations – Working with Company’s technical personnel to gather the necessary information to perform an export jurisdiction determination and classifying the items under the appropriate set of export regulations.
Export License and/or Agreement Application Preparation – Assist with the preparation of information required for filing export license applications and related agreements under the ITAR and EAR, including the provision of strategic advice on government agency interaction.
Export Shipment Reviews and Related Documentation Preparation – Conducting export control reviews of Company’s export shipments, including end-user/end-use screening, classification, and license requirement determination.
OFAC/Anti-boycott Transaction Reviews – Reviewing transactions to assess compliance with applicable OFAC regulations on embargoes / sanctions or anti-boycott requirements.
Assist in preparing voluntary disclosures for submittal to various U.S. Agencies, DDTC Registration and renewal (NOTE: DDTC Registration fees are due directly from Company to the U.S. Government).