Category: ITAR

Appropriate to the Season and to something that should stay with us all throughout the year... On the first day of Christmas my company gave to me- A Management Compliance Policy which establishes my management’s and my company’s commitment to export compliance; On the second day of Christmas my company gave to me- An Export...

It’s almost Thanksgiving and when I think Thanksgiving, I think about traditions. Truthfully, no one in my family even likes turkey and we’ve discussed deviating from eating it every year, but we just can’t do it! Why? Tradition! We have all kinds of traditions at this time of year: fighting over (ahem, I mean breaking)...

DDTC has announced an administrative settlement (Consent Agreement) with the company, AeroVironment, Inc. for violations of the Arms Export Control Act (AECA) and the International Traffic in Arms Regulations (ITAR) in connection with the unauthorized exports of defense articles, to include technical data, failure to properly maintain records involving ITAR-controlled transactions, and violations of the...

They say that change is inevitable and that the only thing constant is change. Most of us do not like change. We like our world to be the way that we are used to and comfortable in, but change is inevitable. The better you are prepared for change, the easier it is to accept and...

The Directorate of Defense Trade Controls (DDTC) has entered into a Consent Agreement with L3Harris Technologies, Inc. (“L3Harris”) for violations of the International Traffic in Arms Regulations (ITAR).  In its Proposed Charging Letter, DDTC alleged a total of one hundred thirty-one (131) violations.  The violations fall into the following categories: Unauthorized Exports of Technical Data...

We all get stuck in our ways sometimes. Some of us have had the same hair since 1980, others of us can’t let go of that old sweatshirt from high school. Some have trouble embracing the latest fashion trends. Those things can all be overlooked, but your Compliance Manual should always embrace the latest regulations....

Capital One is famous for its slogan, “What’s in your wallet?”  But in the world of trade compliance officers, the pertinent question might be, “What’s in your compliance plan?” Earlier this year, OFAC published “A Framework for Compliance Commitments.”  This framework provides direction and insight into what the agency believes are essential elements of a...

The interim rule from the General Services Administration, the Department of Defense and NASA was published on August 7, 2019 and becomes effective today, August 13, 2019.  As a requirement of NDAA 2019, the rule prohibits federal agencies from purchasing telecommunications and video surveillance equipment, along with any “substantial or essential component of any system, or...

Currently, the National Defense Authorization Act (“NDAA”) 2020 is under review in both Houses. Both versions of the Act contain a proposal to amend the Arms Export Control Act (“AECA”), thereby granting India Major Non-NATO Ally Status. Last week the U.S. Senate passed its version including the amendments to the AECA.  At the same time,...

Discussions on the fringes of the G-20 Summit have apparently led to a potential lessening of the restrictions against Huawei and at least some of its affiliates.  These sanctions and the ensuing discussions certainly overshadowed the eight themes of the summit (Global Trade, Economy, Investment, Innovation, Environment and Energy, Employment, Women’s Empowerment, Development and Health). ...