Organizations should closely analyze requirements from their customers who flow down regulatory requirements such as the FAR and/or DFARS to determine if conflicts exists. In an analysis of certain Defense Federal Acquisition Regulations Supplement, I noticed what could be a conflict for those organizations who may seek to use a Voluntary Disclosure as a result of an authorized export. However, if they follow the DFARS in it strictest sense, the VD would not be considered. 

If conflicts exist between an organization’s policies and a customers’s or regulatory requirements then the organization should consider alternatives to policies and procedures in order to maintain compliance while not senselessly walking away from options that can protect the organization.

Subscribe to AEI’s mailing list

* indicates required