ITAR & Export Compliance
CVG Strategy, LLC
Compliance Training, export compliance, Export Regulations
What is ITAR?
CVGS ITAR LOGOThe International Traffic in Arms Regulations (ITAR) detail the regulations governing the export of defense related materials and technologies, including hardware, software, and services. Administered by the (DDTC) Directorate of Defense Trade Controls, (Department of State) the goal of ITAR is to safeguard U.S. national security and further U.S. foreign policy objectives and policies. It provides definitions of important terms, with information and procedures for registration, licenses, agreements, general policies, violations, penalties, and administrative procedures.
Under ITAR §122.1(a) a company is required to register if it manufactures defense articles or provides defense services even if the product is never exported.
What is the EAR?
The EAR (Export Administration Regulations) are the rules by which the (BIS) Bureau of Industry and Security (U.S. Department of Commerce). It regulates and controls exports of goods from the United States. All goods and services that are not covered under the State Department’s US Munitions (USML) list fall within the preview of the EAR, under the Commerce Control List (CCL). Now that Export Control Reform (ECR) is taking effect, attention to the EAR is even more important.
GLOBE W Shipping CartTaken from the BIS Website: the “BIS Mission: Advance U.S. national security, foreign policy, and economic objectives by ensuring an effective export control and treaty compliance system and promoting continued U.S. strategic technology leadership. The mission of the Bureau of Industry and Security (BIS) Export Enforcement is to protect U.S. national security, homeland security, foreign policy, and economic interests through a law enforcement program focused on: sensitive exports to hostile entities or those that engage in onward proliferation; prohibited foreign boycotts; and related public safety laws.”
Authority is granted the BIS under the Export Administration Act of 1979, as amended, (Pub. L. 96-72, 93 Stat. 503, 50 U.S.C. app. 2401 – 2420). And the International Emergency Economic Powers Act, as amended, (Pub. L. 95-223, 91 Stat. 1628, 50 U.S.C. 1701 – 1706). Additional authority is granted from a series of Presidential Executive Orders.
What does it mean to businesses?
If your company deals with defense equipment, supplies, services or technologies, the ITAR and Export Compliance regulations specify that you share these items only with U.S. persons and organization unless you receive authorization from the Department of State or qualify for a special exemption. If your company offers dual-use or specially classified items under the control of the Commerce Control List (CCL) and the Export Administration Regulations, similar restrictions on access are applicable. Companies and individuals may face potentially heavy fines or penalties for providing foreign persons with access to ITAR or EAR-protected and restricted items.
What is compliance?
Registration with DDTC (if required)
Active and documented compliance policy and procedures
Denied parties watch list screening
Internal audits and continuous improvement discipline
Third-Party Audits – Annual
If you are part of a large corporation with an ITAR or EAR compliance related employees or a small company with a part-time compliance person, CVG Strategy has the compliance and training programs to fit your exact needs. We even serve as an outsourced Export Compliance Officer for some clients, who don’t have the bandwidth to dedicate to the function but need it done on a part-time basis where we can perform this on their behalf.
CVG Strategy, LLC is recognized the world over as the premier provider of customized ITAR & Export Compliance Programs and Training that addresses critical U.S. Government regulations, from Export Administration Regulations (EAR), to the International Traffic in Arms Regulations (ITAR) and Office of Foreign Asset Controls (OFAC) and other regulatory agencies and more.
, export compliance
, Export Regulations
, Export Training