Sep 08, 2008 hello alllooking for a little assitance today. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. This document promotes good export compliance practices. Compliance with this strict set of regulations is vital because it helps to ensure defense technology and related technical data does not. Officer of the company designated persons empowered official itar required written procedures and processes exportimport compliance manual. Identification, receipt and tracking of itar controlled itemstechnical data.
We make itar compliance easy avoid spending hundreds of hours wading through government regulations or wasting budget on overpriced consultants. International traffic in arms regulations itar under the international traffic in arms regulations itar. Employees are expected to be familiar with and to follow. This export compliance manual manual and the policies and procedures contained herein, are designed to ensure that ku complies fully with all applicable u.
Itar means the international traffic in arms regulations, as amended, 22 code of federal regulations 120 which are promulgated and implemented by dos and designed to regulate items on the u. Compliance requires a documented system, and there are numerous areas that need to be addressed. Here is a listing of the general topics that need to be covered. Tips for itar export compliance procedures reliant defense. Dfar companies that provide defense goods and services need to know the rules. The international traffic in arms regulations itar and the export administration regulations ear are the main usg export rulebook governing defense articles. Compliance letter guidelines all domestic customers in the united states must submit an itar compliance letter to cloud cap technology before receiving software access. How to develop an export management and compliance program and manual how these guidelines can help these guidelines were developed to assist companies in establishing, or enhancing, an export management and compliance program emcp. University of wyoming export compliance manual updated july 2015 iii.
Sep 05, 2012 six tips for effective itar export compliance procedures september 5, 2012 by cole blumer too many times, export compliance procedures are a meaningless clump of definitions and a menagerie of content collected from seminars or templates found on the internet. International traffic in arms regulations itar under the international traffic in arms regulations itar, 22 c. In addition to the above four mandatory readings, the documents below are also quite important. Ssi government property management plan 4 ssi will investigate and report all incidents of loss, damage, destruction, or theft lddt of gfp to the government or prime. In conclusion, this is not a guide 100% itar compliance. Download your complete itar compliance manual and training program today. Page 4 of 35 university of wyoming export compliance manual updated july 2015 iii. As a customer to electromech, you may receive defense articles andor technical data as defined. Sowell management servicessms the company or firm has adopted the following policies and procedures for compliance as a registered investment adviser under investment adviser act of 1940 advisers act. Department of state, directorate of defense trade controls ddtc.
This compliance manual is intended to apply, where applicable, toall relationships between sprenger and other health care providers and. The sample export compliance manual published by originally began as a consulting project for one of the largest defense contractors in the united states. Export control laws and regulations, to identify key export compliance issues related to research. If youre like most organizations, youll reply with something like. I will be going to training on the subject soonbut want to get a head start on how to lay out a itar compliance manual or work instruction. Export compliance manual and verification export compliance manual rev. Use with the itar cdrom by customs compliance consulting inc. Does anyone have an itar compliance manual sample they could possibly share. Regulations, rules, and lists for specifying who or what is considered export sensitive and where export controls apply are subject to change. For example, a commercial radio that would normally not be controlled under the itar becomes a controlled defense article if it contains an itarcontrolled microchip. It has useful advice, recommendations, technical answers, and much more. For example, eccn 5e001 technology may be exported to a university. Use this comprehensive checklist to conduct annual compliance audits and detect itar non compliance based on export clearance requirements, itar controlled technical data, use of itar exemptions, and more.
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. Whenever faculty andor students are engaged in teaching or research related to controlled items, information. 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. I recommend a threeprong strategy for complying with itar. Articles, services, and related technical data that are designated as defense articles or. As an example, some companies choose to designate a. These regulations are regularly updated and revised to reflect change in the international political and security climate, as well as technological development. It does not purport to address all relevant trade compliance issues itar regulations 120 that may apply to a companys exporting activities. Comprehensive operational compliance programs include manuals that articulate the processes to be.
This manual is an example and is intended only as a guide. Export controls compliance manual research compliance rice. Well, jim is in charge of our exports and he can tell you everything you need to know. Itar compliance manual samples risk analysis, quality. After publication, we adapted many of the industry specific procedures to fit a more general company profile and serve as a template for the export community. An export compliance program is a not required by the ear. Export compliance doesnt have to be expensive, time consuming, or hard. University of wyoming export compliance program updated 114 under the international traffic in arms regulations itar, 22 c. A government agent contacts your company and asks to see a copy of your itar compliance manual.
Itar compliance manual pdf the specific objective of this itar guide is to answer the above question by providing a for pdf ebooks about sample itar compliance manual,itar. Export controls compliance policy vinyl technology. Develop an exportimport compliance program which will consist of the following identification of persons responsible within your company sr. For example, a commercial radio that would normally not be controlled under the. These include the companys export compliance manual, which is the main compendium of written policy procedures, checklists and forms to which all employees must adhere. Government property management plan synectic solutions. Under this export controls compliance policy the policy, violate the no employee may international traffic in arms regulations itar, administered by the u. Classification export decision making and product matrix. Bill sowellis designated as the companys chief compliance office r cco and is responsible for ongoing compliance matters of the company. Six tips for effective itar export compliance procedures september 5, 2012 by cole blumer too many times, export compliance procedures are a meaningless clump of definitions and a menagerie of content collected from seminars or.
Well, jim is in charge of our exports and he can tell you everything you. The manual applies to the ku community, including its faculty, staff, students, affiliates, visitors, vendors and contractors. The international traffic in arms regulations itar and the export administration regulations. The itar frequently asked questions guide contains answers to over 70 questions most often asked by exporters who are regulated by the department of state and the us government. Munitions list, including defense articles and defense services and related technical data. Export of defense articles and services international traffic in arms regulations under the international traffic in arms regulations itar, 22 c. This is intended as a tool for evaluating the most common.
Export compliance policy and management commitment. This thompson coburn llp trade compliance handbook is intended to provide an overview of international trade regulatory compliance issues and related terms to corporate general counsel, as well as compliance and audit personnel. Vanderbilt export compliance manual page 5 of 40 last revision march 26, 2018 5 purpose the vanderbilt university export compliance manual manual is intended is to provide guidance on u. Determining whether the product is defense article c. A template for an itar perspective and print online pdf submit itar manual example. Three step strategy classification simply means you need to determine if your product is on the munitions list and subject to itar. Export control compliance manual northeastern university. The elements of an effective export compliance program bis us. Pat crow wpc to be in full compliance with all applicable laws and regulations. Itar compliance manual pdf books reader itar compliance manual downloads at download free pdf files,ebooks and documents export compliance program manual university itar export compliance export rules the international traffic in arms regulations do not list a definition for the term itar compliance, sample export. Sample compliance manual table of contents itc strategies. The international traffic in arms regulations itar proscribed countries.
Whenever faculty andor students are engaged in teaching or research related to. Sample export compliance manual itar export compliance. For example, a commercial radio that would normally not be controlled under the itar becomes a controlled defense article if it contains an itar controlled microchip. The sample export training presentation contains more than 50 slides that. Key actors responsible for export control compliance. Technical data may include drawings or assembly instructions, operations and maintenance.
A compliant itar program should clearly identify the corporate commitment to meeting and maintaining all itar guidelines. For example, military aircraft are itar controlled as well as the engines and navigational controls even though such components may have other. Mcvey williams mullen june2, 2014 the following is a checklistof key issuesfor companiesto consider in assessingcompliance under the international traffic in arms regulations itar. Export management and compliance program the purpose of this document is to provide overall guidance on export control regulations and washington university export control internal policy and procedures. The international traffic in arms regulation itar is the defense product and service providers guide book for knowing when and how to obtain an export license. Export compliance policy and management commitment c. Such reports will include, in accordance with far 52. This compliance manual formalizes sprengers commitment to compliance by establishing sprengers standards of conduct for its nursing facilities, sprenger hospice, inc. The international traffic in arms regulations itar, 22 cfr 120 implements the aeca. This manual is designed to assist you in complying with u. A page 4 of 9 proprietary and confidential this comprehensive operational compliance program includes instructions and makes reference to. Ku export compliance manual office of export compliance the. Export compliance program policies and procedures manual. If you have any questions regarding the material contained in this export compliance program manual, please contact us office of research integrity and ompliance export ontrols office.
Please note that sections highlighted in red will require editing for the company university research group needs. Note that the itar uses the term blueprints to cover drawings and assembly instructions. The purpose of this manual is to provide the university community the essential aspects of the laws and regulations concerning exports, confirm our policy for compliance, andlainexp how the binghamton. Acronyms are defined in the list of abbreviations, page 4. This publication of the international traffic in arms regulations itar is intended to be a convenient reference guide for the reader. Checklist of complianceissues underthe internationaltraffic in arms regulations by. Under the international traffic in arms regulations itar, 22 c. The international traffic in arms regulations itar is a set of u. Export controls do not only apply to physical shipments or transmissions abroad. The official versions of the regulations contained herein are set forth in the annual printings of title 22 of the code of federal regulations cfr, as amended in the federal register fr.
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