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Last week, DDTC released a proposed charging letter and subsequent consent agreement, alleging 125 charges of ITAR violations against Raytheon Company and its subsidiaries. Here are four key lessons for export compliance officers and corporate counsel who are interested in avoiding similar ITAR compliance problems for their companies.

Last week, President Obama’s Export Control Reform (ECR) efforts took a big step forward with a final published rule that, once implemented, will begin moving items and technologies from ITAR to EAR controls. The first categories of USML items affected by this rule are: Category VIII (Aircraft and Related Articles), Category XVII (Classified Articles), and XII (Articles, Technical Data and Defense Services Not Elsewhere Enumerated).

A former employee of L-3 Communications’ Space and Navigation Division was recently sentenced to 70 months in federal prison for exporting U.S. technology to China. Sixing Liu, 49, (aka “Steve Liu”) of Flanders, New Jersey, was convicted on nine counts, which range from lying to federal agents to six counts of International Traffic in Arms Regulations (ITAR) violations.

Empowered Officials carry a lot of responsibilities under the definition found in ITAR 120.25. But do you really understand everything that is required of you in this role? And are you prepared to handle that responsibility for your company's export compliance?

Recent news stories point to an ongoing investigation which claims that NASA may have been involved in illegal exports of sensitive technologies to China. But what, if anything, is being done to prevent future exports of sensitive technology?