Question: Hello,for a little more than a year, our company has involved an individual (U.S. citizen) to help facilitate the exporting of our products, many of which are listed on the USML, to parts of the EU and elsewhere. It is evident the actions undertaken by this individual, on our firms’ behalf, constitute “brokering activities”. […]
Question: What measures should be taken to prevent noncompliance on patent application for product that could be developed for potential ITAR use? Answer 1: I may be a little out of date, but generally to be considered ITAR, a product would have to be developed specifically for military use (not withstanding potential dual use possibilities). […]
Question: I am looking into hiring a Foreign Person for some consulting work outside of the U.S. They would not be a direct hire, but instead would be hired as a contractor through a staffing agency in their home country. We would need to obtain a DSP-5 to share ITAR-controlled tech data and my question […]
Question: The company has purchased a server (hardware) which will be configured in the U.S. with customized software that is ITAR-controlled prior to shipment to the United Kingdom. The ITAR-controlled software will be exported to the UK foreign entity under an ITAR exemption. Generally speaking, EEI filings are not required for intangible exports (i.e., software). […]
Question: I have a potential non-compliance risk related to a temporary export under the ITAR. Product under the license was to have shipped to a specific country yet somehow ended up in a completely different country where the risk is separate potential violation of EU export requirements because exporting the product from the EU may […]
Question: We are in the final implementation of our Canadian Controlled Goods Program registration that will enable us to receive ITAR technology in our Canadian facility. One area of concern is with visitors. I think it comes from the idea that the CCGP requires an individual access as well as the company’s access program. In […]
Question: My company is registered with the DDTC, and we will soon be selling off one of our subsidiaries that is on the registration. It is being sold off to a Canadian investment firm. Can someone help me interpret the ITAR regulations? Are we to follow 122.4(a)(2)(v) (5 day written notice) or 122.4(b) (60-day notice […]
Question: We have a site in Canada and we are going to be doing some work that will require us to receive ITAR technology from our customers. We have just received our Canadian Controlled Goods Program certification and are working on next steps. Under the CCGP, all employees who will work with the technology need […]
Question: Hello, Details: I am new to an organization that has an open DSP-5 License, I don’t know what details were submitted 2 years back when the license was requested, but it covers two line items: 1 – the commodity with a quantity of 3,000 and 2 – Technical Data: Quality assurance test data with […]
Question: We all understand that if you make a design change to an EAR controlled part for a military end use that it will likely be caught in “specially designed” and controlled under 600 series or move directly to ITAR. Is there ever a circumstance when the reverse could be true? For example, a component […]
Question: We have a product that we build in the UK and falls under UK dual use controls, it ships from the UK under a UK OGEL Under the US controls, this item is an ITAR product. For this reason, we don’t sell the product to the US market because it makes returns and product […]
Question: Greetings members. In this scenario: A foreign subsidiary of a US parent company intends to manufacture defense related parts for a foreign customer. The foreign subsidiary and foreign customer are located in the EU and within the same country (just as a note). Can anyone shed light on what the ITAR implications would be […]
