Built on the microsoft office and sharepoint platforms, titus itar solutions are easy to implement because most end users are already familiar with these environments. Compliance with this strict set of regulations is vital because it helps to ensure defense technology and related technical data does not. Building an effective itar compliance program can seem like a daunting task, but theres no need to start from scratch. A good consultant will be able to understand your business needs, and bring forward a customized, practical solution that actually works. University of georgia export compliance program management. Engineering, physics, space sciences, research with lasers, research with encrypted software, and re search with controlled chemicals, biological agents, and toxins. Cuba, iran, north korea, sudan, syria, or crimea region of ukraine. Ddtc is currently in the process of updating the online material supporting the submission of licensing forms. Nov 05, 2014 so, in light of the itars intent to regulate not only the export of physical defense articles but also the transfer to foreign persons of u. I have entrusted them time and again with itar solutions for both of my corporations, all of which dealt with us government and military applications for which there can be no mistakes. The titus family of itar solutions work within current systems to help manage itar compliance by both labeling information and restricting access. The itar controls hardware, technical data, software and defense services relating to the items listed on the united states munitions list usml located in the itar.
Lack of export compliance program results in ddtc fine. Built on the microsoft office and sharepoint platforms, titus itar solutions are easy to implement because most end users are. Atlassians risk management program is at the focal point of our risk and compliance team and serves as foundational element of our decision making process. More than ever before, companies today need to comply with all the u. If your product is on the list, everything else flows from this. Compliance program guidelines mks projects identified via the job folder information as itar will involve the receipt andor use of technical data that is controlled under united states export control laws. What you need to know article, you will want to read that to get a basic level of itar compliance understanding prior to reading this article. Itar violations can be harmful to the national security and foreign policy of the u. A good compliance program has some widely accepted key components. International traffic in arms regulations itar, 22 c. Our itar201 briefing privdes depth for management and compliance personnel.
We rely on everyone who deals with usml items to help us protect our nations sensitive technologies. 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. Please be sure to submit license requests through deccs to ensure the submissions adhere to the current rule set. Export compliance program policies and procedures manual. What is an itar compliance program and why do you need one. 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. Orchid advisors assists firearms manufacturers, distributors and retailers in achieving compliance and operational excellence through education, technology, software and consulting solutions that reduce risk, cut costs, and provide expert guidance to make our clients business more successful and efficient. Sensitive information deemed critical to the defense of the nation is subject to strict controls over its movement, use, and storage. Itar compliance software for all your trade compliance needs 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. International traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list usml. Specific questions, concerns, or analysis should be directed to dan runge, export compliance officer, at 706. Introduction to export and sanctions compliance export control compliance at uga 3 how and why did this program develop. These export control laws are designed to prevent unauthorized foreign nationals from procuring any sensitive information.
Itar compliance in the cloud focuses on ensuring that information considered technical data is not inadvertently distributed to foreign persons or foreign nations. To ensure compliance with the itar, the directorate of defense trade controls strongly encourages registered exporters, manufacturers, brokers, and others engaged in defense trade, to maintain compliance programs that assist in the monitoring and control of exports and other regulated activities. The office of defense trade controls compliance strongly advises parties engaged in defense trade to establish and maintain an itar export compliance program. Sensitive information deemed critical to the defense of the nation is subject to strict controls over its. Excelerates team of professionals is available to your company, for the defined number of hours, by email or phone, to satisfy any itar question or. By jeff grody principal and export itar practice lead. What features should your itar compliance program contain. Download services brochure pdf evolutions in business compliance support fees.
Manufacturers, exporters and distributors of defense and defense related articles must demonstrate and document an international traffic in arms regulations itar compliance program. Darling admitted that its lack of qualified personnel, itar compliance training, classification system, and documented export compliance program are what ultimately led them to violate the itar. Itar compliance has been the newest regulation to affect the manufacturing industry. Pat crow wpc to be in full compliance with all applicable laws and regulations.
An itar compliance program is established based on a top level set of guidelines provided by dtc and industry accepted standards for compliance execution. Compliancecommercial and military compliance support. Integrating enterprise risk management throughout an organization improves decisionmaking in governance, strategy, objectivesetting, and daytoday operations. In conclusion, this is not a guide 100% itar compliance. Whether it is for our itar compliance program, or oneoff questions about legalities and process, ics has been there to answer my queries immediately and given. With technical data, its also a good idea to tag each page with an itar notice or marker so employees dont accidentally share controlled information with unauthorized. Itarear compliance is offered at center for corporate education at stony brook university. Enforcement actions by regulatory agencies are increasing. So, in light of the itars intent to regulate not only the export of physical defense articles but also the transfer to foreign persons of u. The first cornerstone concept under itar itar contains a list of products called the u. Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be itar compliant. The individual is a citizen of one or more of the following countries. The us government requires having in place and implementing a documented itar compliance program, which should include tracking, monitoring and auditing of technical data. At virtustream, we take an extremely proactive approach to our compliance program to make sure your compliance requirements are met in our cloud infrastructure.
The international traffic in arms regulations itar is a set of u. Once an itar program is developed, an internal audit process needs to be established to monitor the implementation and effectiveness of the program. Itar compliance software for all your trade compliance needs. The department of state administers the international traffic in arms regulations itar. If your company is involved in exporting any defense products, services, or related technical data, youre probably already familiar with the international traffic in arms regulations itar. An itar compliance checklist is a tool used by arms suppliers to easily determine if they are itar compliant, establish an identification system for itarcontrolled products, and implement an effective itar compliance program. 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. Use this comprehensive checklist to conduct annual compliance audits and detect itar noncompliance based on export clearance requirements, itarcontrolled technical data, use of itar exemptions, and more. University of wyoming export compliance manual updated july 2015 iii. Munitions list usml if your product is on this list, it is subject to these controls. Aws govcloud us supports compliance with united states international traffic in arms regulations itar.
If you look down the list, you will see that the majority of headings a lot. Washingtonbased export attorney, kay georgi, says that one of the most common mistakes among businesses is the lack of a clearly communicated, accurately enforced, and properly documented itar compliance program. The itar contains the united state munitions list usml, which includes defense articles and related technical data that are controlled for export purposes. 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. Export of defense articles and services international traffic in arms regulations under the international traffic in arms regulations itar, 22 c. Itar international traffic in arms regulations and determination of the license need are the crucial steps before an export of a defense article and before providing a defense service to nonu. In addition to export controls, the office also works to assure compliance with federal economic and trade sanctions that bar. International traffic in arms regulations itar the itar requires.
Export compliance management and compliance program itar. Nov, 2014 by jeff grody principal and export itar practice lead. 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. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. The following are factors to consider in determining the applicability of export regulations. To ensure compliance with the itar, the directorate of defense trade controls strongly encourages registered. These guidelines are intended to promote awareness of the regulations and provide basic guidance on university of georgia compliance procedures.
The central platform makes it easy to manage your guests and their records, ensuring that company policy standards and compliance protocols are followed and adhered to at all times. Our itar 201 briefing privdes depth for management and compliance personnel. Export control compliance program guidelines july 2018. Jul 15, 2019 learn about itar compliance in data protection 101, our series on the fundamentals of information security. Develop an exportimport compliance program which will. As a part of managing a comprehensive itar compliance program, companies that are subject to itar export regulations must control unintended exports by restricting access to protected data to us persons, and by restricting physical location of protected data to the us. 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. This program incorporates the guidance from the directorate of defense trade controls ddtc and bureau of industry and security bis, the office of foreign assets control ofac and the office of antiboycott compliance oac. Aug 02, 2016 using a visitor management system as a basis for your itar compliance program ties together and automates essential visitor tasks and processes.
About itar compliance solutions we have the capabilities and experience to deliver the solutions you need to be actively compliant. Our itar 101 training video lasts 10 minutes and gives an introduction to itar and compliance. Ear commerce dualuse goods, technology, chemicals and software itar state military items. Companies and their decisionmakers face exceptionally high legal. Export management compliance program emcp automated export system compliance aes conflict mineral compliance. So, in light of the itar s intent to regulate not only the export of physical defense articles but also the transfer to foreign persons of u. This course will provide you with an understanding of export compliance under international traffic in arms itar and the export administration regulations ear, with a focus on the continuing changes under export control reform ecr. International traffic in arms regulations program and. Software overview access the awardwinning enterpriseclass application management and security software that powers the virtustream enterprise cloud.
Our itar101 training video lasts 10 minutes and gives an introduction to itar and compliance. A definition of itar compliance international traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list usml. The program should include areas such as auditor training, documentation of audit results, yearly schedules of audit activities and actions to be taken if violations are noted. The cui framework applies to two important export control laws including the international traffic in arms regulations itar which covers defense technology, software, or other information whose export could reasonably be expected to adversely affect us national security, and the export administration regulations ear. Pat crow wpc to be in full compliance with all applicable. Your organization needs to understand what itar compliance is and what responsibilities you have to ensure your business. Under the international traffic in arms regulations itar, 22 c. Using a visitor management system as a basis for your itar compliance program ties together and automates essential visitor tasks and processes. Itar compliance software and usml classification ecustoms. Munitions list usml compliance with this strict set of regulations is vital because it helps to ensure defense technology and related technical data does not fall into the hands of. Export control compliance program guidelines january 2019.