This publication of the international traffic in arms regulations itar is intended to be a convenient reference guide for the reader. International traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list usml. Compliance with the international traffic in arms regulations itar is both necessary and worthwhile to include an itar compliance program andor an itar compliance manual. The sample export compliance manual published by originally began as a consulting project for one of the largest defense contractors in the united states. International traffic in arms regulations itar, enforced by the office of defense trade controls in. So, if an item is on the list such as a navigational device the software used to run that device is also on the list, and the technical data related to the device is on the list. Compliancecommercial and military compliance support. Lists of export controlled items, information and software. Compliance ctp training, management, export compliance.
Government regulations that requires all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data to be itar compliant. Administration regulations ear1 and the department of state through its international traffic in arms regulations itar,2 as well as those imposed by the treasury department through its office of foreign assets control ofac. Toolkit for internal compliance is a great tool for any itar program. Typically, this access is citizenship based with authorization being defined by the u. Knowledge of corporate internal controls that have been established and implemented to ensure compliance with the aeca and itar. More than ever before, companies today need to comply with all the u.
An effective compliance manual can help you avoid costly fines and penalties. If you look down the list, you will see that the majority of headings a lot. If youre like most organizations, youll reply with something like. Knowledge and understanding of when and how the aeca and itar affect the company with itar controlled itemstechnical data. Licensing or other authorization is not required in situations where the technology or technical data is controlled for exportrelease to foreign persons. Ctp has been developing and delivering export control compliance solutions in the u. This manual is an example and is intended only as a guide. The official versions of the regulations contained herein are set forth in the annual printings of title 22 of the code of federal regulations cfr, as amended in the federal register fr.
Sample export compliance manual itar export compliance. A government agent contacts your company and asks to see a copy of your itar compliance manual. Importance valid itar compliance manual watson lawyers. Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be itar compliant. A good compliance program has some widely accepted key components. In conclusion, this is not a guide 100% itar compliance.
At its most basic, being itar compliant means following all of the requirements of the international traffic in arms regulations itar. The sia publishes manuals and material related to itar. Export compliance program policies and procedures manual. Itar compliance software and usml classification ecustoms. Export management compliance program emcp automated export system compliance aes conflict mineral compliance. Export control compliance manual northeastern university. Itar regulates the manufacture, sale, and distribution of the military, defense, and spacerelated hardware, data, and documentation. Itar compliance software for all your trade compliance needs. The purpose of this manual is to provide guidance on u. International traffic in arms regulations itar3 under the itar, ddtc administers the export and reexport of defense articles, defense services and related technical data from the us to any foreign destination, or to any foreign person, whether located in the us or abroad.
Nov 02, 2015 the compliance the supplier wants you to certify is that your company has the basic internal controls to secure itar products and all the technical data associated with those products, such as specification sheet prints, operating instructions, etc. International traffic in arms regulations itar is a set of u. If you have any questions regarding the material contained in this export compliance program manual, please contact us office of research integrity and ompliance export ontrols office. Technical data refers to drawings, algorithms, manuals, any information.
T he objective of itar compliance is to establish executable policies and procedures that will allow your company to successfully manage itar controlled data. Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be. Published by the us state department in its international traffic in arms regulations itar, the us munitions list addresses items, software and technologies that are primarily defenserelated in application. Identification, receipt and tracking of itar controlled itemstechnical data methodology used, specifically tailored to corporate structure, organization, and. Scope and objectives of kus export compliance manual this export compliance manual manual and the policies and procedures contained herein, are designed to ensure that ku complies fully with all applicable u. The international traffic in arms regulations itar is a set of u. Rules, regulations, and laws related to export control are updated frequently. Firearms, close assault weapons and combat shotguns.
Develop an exportimport compliance program which will consist of the following identification of persons responsible within your company sr. If your product is on the list, everything else flows from this. Officer of the company designated persons empowered official itar required written procedures and processes exportimport compliance manual. This manual is meant to serve as a guide to provide basic information related to export controls. The first cornerstone concept under itar itar contains a list of products called the u. Export control compliance manual 2016 export control laws are complex and specific to each circumstance. Page 3 of 35 university of wyoming export compliance manual updated july 2015 overview of export controls i. This manual is designed to assist you in complying with u. We offer a full slate of compliance services at affordable rates to. Itar compliance, itar regulations, and export licensing are just a few of the topics covered on by excelerate, inc. Itar export compliance export rules and regulations. The hardest part of creating an export compliance program is knowing where to start. In order for data to be subject to itar, an it workload or type of data has to be deemed an export according to the us munitions list usml. Vanderbilt export compliance manual page 5 of 40 last revision march 26, 2018 5 purpose the vanderbilt university export compliance manual manual is intended is to provide guidance on u.
Expert import and export compliance services ctp has unsurpassed technical experience in export control compliance. Munitions list usml if your product is on this list, it is subject to these controls. If your company falls under these categories, the following information will help answer some of your questions as. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. Directorate of defense trade controls dtc issued license and. Export controls compliance manual digital version outlining an export management and compliance program emcp at ndsu research integrity and compliance office of research and creative activity implemented, revised, and updated.
Here is a list of itar compliance requirements and penalties you need to know. Introduction the export of certain items, including but not limited to technology, software and hardware, is regulated and. Our itar compliance software can help you navigate the international traffic in arms regulations itar, which govern the permanent and temporary export of defense related goods, technologies, and services on the united states munitions list usml. It does not purport to address all relevant trade compliance issues itar regulations 120 that may apply to a companys exporting activities.
The purpose of cornell universitys export control compliance manual is to provide the basis for the operational program and procedures which manage export decisions and transactions in compliance with the three major components of the export control laws and regulations, i. Under the international traffic in arms regulations itar, 22 c. Pat crow wpc to be in full compliance with all applicable laws and regulations. Itar compliance in the cloud focuses on ensuring that information considered technical data is not inadvertently distributed to foreign persons or foreign nations. The manual applies to the ku community, including its faculty, staff, students.
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