ITAR Compliance and Export Control Solutions

The International Traffic in Arms Regulations (ITAR) controls export and temporary import of defense articles, defense services, and related technical data per the Arms Export Control Act.

ITAR classifies items using the United States Munitions List (USML) spanning military aircraft, missiles, firearms, explosives, and related technologies.

Organizations engaged in USML activities must register with the Directorate of Defense Trade Controls (DDTC) and comply with authorization, recordkeeping, and reporting requirements.

ITAR violations carry severe penalties including fines, debarment, and criminal prosecution.

Effective compliance requires systematic processes addressing technology access, export authorization, and foreign person controls.

Proper ITAR compliance begins with accurate commodity classification determining whether items fall under USML jurisdiction.

Classification requires technical analysis evaluating item characteristics against USML category descriptions.

We conduct commodity jurisdiction reviews examining design specifications, functional capabilities, and intended applications.

Classification complexity arises from overlapping USML and Export Administration Regulations (EAR) jurisdictions.

Our classification methodology documents jurisdiction determinations supporting audits and export licensing applications.

We maintain classification records tracking commodity jurisdiction requests and DDTC determinations.

Organizations manufacturing or exporting USML items must register with DDTC unless qualifying for exemptions.

Registration requires detailed disclosure of business activities, ownership structure, USML categories involved, and foreign affiliations.

We prepare registration applications ensuring completeness and accuracy.

Registration maintenance demands annual compliance certifications updating business information and paying registration fees.

We track registration renewal deadlines preventing lapses that would prohibit export activities.

Our registration support includes debarment screening, beneficial ownership disclosure, and foreign ownership analysis.

Most USML exports require prior State Department authorization through licenses or agreements.

We manage export authorization strategies selecting appropriate license types based on transaction characteristics.

DSP-5 licenses authorize permanent export of defense articles.

DSP-61 agreements cover temporary export for trade shows and demonstrations.

TAAs authorize export of technical data and defense services.

We prepare authorization applications documenting end-users, end-uses, and item descriptions.

Our licensing database tracks authorization status, expiration dates, and compliance conditions.

We monitor license provisos ensuring adherence to approval stipulations.

ITAR broadly defines technical data as information required for defense article design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification.

Technical data export includes electronic transmission, visual inspection enabling information derivation, and oral exchanges of information.

We implement technical data controls including classification marking, access restrictions, transmission logging, and foreign national screening.

Our technical data management solutions integrate with engineering systems preventing inadvertent disclosures.

We establish clean room procedures enabling foreign national participation without ITAR-controlled information access.

ITAR deems technical data or defense article release to foreign persons as exports requiring authorization regardless of location.

Foreign persons include non-US citizens, non-permanent residents, and foreign entities regardless of location.

We implement foreign person controls screening personnel citizenship status before granting access to ITAR-controlled information.

Access control systems enforce physical and logical segregation preventing unauthorized foreign person access.

Our vetting procedures verify citizenship documentation and track visa status ensuring ongoing compliance.

We establish visitor management processes controlling foreign national facility access.

ITAR mandates retention of export authorization documentation, shipping records, foreign party information, and correspondence with DDTC.

Records must be maintained for five years from export date or authorization expiration.

We establish recordkeeping systems organizing export documentation by authorization number.

Our retention management ensures timely record disposal after retention periods while preserving audit trails.

ITAR requires reporting various activities including political contributions, certain agreements, and unauthorized disclosures.

We implement reporting procedures ensuring timely notification satisfying regulatory obligations.

DDTC conducts compliance audits examining registration accuracy, authorization compliance, and recordkeeping adequacy.

We prepare organizations for DDTC audits through internal compliance reviews identifying potential violations.

Our audit preparation includes documentation review, employee interviews, and corrective action implementation.

When violations occur, voluntary disclosure can mitigate penalties.

We evaluate disclosure requirements, prepare disclosure submissions documenting violations and remedial measures, and engage with DDTC during investigations.

Our compliance program development reduces violation risk through employee training, standard operating procedures, and continuous monitoring.