Corporate ITAR Compliance
The objective of ITAR compliance is to establish executable policies and procedures that will allow your company to successfully manage ITAR controlled data. Typically, this access is citizenship based with authorization being defined by the U.S. Directorate of Defense Trade Controls (DTC) issued license and agreement documents. The penalties for not securing ITAR controlled data can be significant and have lasting effects on business with the United States.
Unlike other programs, like ISO, there is no "certification" process associated with ITAR compliance. An ITAR Compliance Program is established based on a top level set of guidelines provided by DTC and industry accepted standards for compliance execution. There will be no governing body reviewing and certifying your company's compliance program by instead a s specific set of compliance elements must be met to be considered a viable compliance program by DTC. These include:
- A documented corporate commitment to ITAR compliance by senior management.
- Methodology for identification, receipt and tracking of controlled items and technical data.
- A procedure for screening customers, carriers and countries.
- Description and procedures for maintaining proper ITAR records.
- How internal monitoring and audits will be performed to ensure the integrity of compliance.
- An explanation and process for educating, training and guiding all employees related to the ITAR.
- Procedures for notification of potential violations to the ITAR.
In addition to and as part of ITAR compliance your company may need to be registered with DTC. If you are a foreign company you may need to register as a "Foreign Broker" which depends on the company's role with the end user.
The services that Excelerate will provide in association with establishing your ITAR Export Compliance include the following:
- Registration: Evaluation and support, as required, to become registered with DTC.
- Technology Control Plan (TCP): Establish a TCP for your company that satisfies the compliance elements required by DTC.
- ITAR Training: Provide ITAR training to the compliance team, employees and management on how to work in association with the ITAR.
- Audit: Establish an Audit Plan for annual execution to ensure compliance is maintained.
- Review: Review any current license and agreement documents to identify any concerns and assist the compliance team in managing existing efforts.
Excelerate has a successful record of establishing and monitoring ITAR Compliance Programs for many customers. We suggest that all new companies select our Starter Bundle for a quick and easy implementation of your ITAR Compliance Program. Just give us a quick call or send an email to get started.