Question: I am preparing a voluntary disclosure for an ITAR part that shipped accidently, as there was no hint from any of the parties involved or the description of the goods that this defense article was indeed an ITAR part. So, my question is how do I go about revising the EEI? Is my only […]
QUESTION: I was very surprised to learn that on the new DECCS (ITAR) licensing application, a user cannot be both a Drafter and an Empowered Official. I confirmed this with DDTC although there is no regulatory basis for this limitation. In our organization, we have well-qualified individuals who are appointed Empowered Officials overseeing multiple locations […]
QUESTION: Is anyone else seeing this requirement in their 2020 ITAR renewal registration letter? We also require that you provide information on how you ensure that foreign persons will not have access to defense articles without written authorization from the Directorate of Defense Trade Controls, as required by ITAR Part 123, within 30 days to […]
QUESTION: I am now the EO for a company and have been here approx. 6 months. In reviewing ITAR compliance, I discovered that we are not registered. I am trying to determine whether I simply need to re-register the business or if we have a larger issue. We make products covered by ITAR but have […]
QUESTION: I am now the EO for a company and have been here approx. 6 months. In reviewing ITAR compliance, I discovered that we are not registered. I am trying to determine whether I simply need to re-register the business or if we have a larger issue. We make products covered by ITAR but have […]
QUESTION: Our facility produces both ITAR and 600 Series controlled product. The IT group would like to hire a Canadian/Great Britain citizen to work on the MRP system. Would a license from both State and Commerce Departments be required? ============ Answer: If they have access to the 600 series and ITAR data then of course […]
QUESTION: How do you classify technology (EAR) or technical data (ITAR) to determine who it can be shared with? Do you start with the hardware classification for every item and then extrapolate the technology classification, assign categorical tech data controls for entire programs, or use another method? And once a technology classification is determined, do […]
QUESTION: I have come across differing opinions or interpretations of 126.1 with respects to”…when the recipient is a U.S. Government department or agency…,” specifically what it means by “recipient,” so I have a question regarding use of exemptions for exports to proscribed/prohibited countries. If company A, which is neither a U.S. Government department or agency […]
QUESTION: If it’s a Japanese company located in California, is this Japanese company a foreign person by ITAR definition? ========== Answers: Any foreign corporation/business/organization/group not incorporated or organized under U.S. law is considered a foreign person ========== That would depend on a number of factors. Start by reviewing the California entity’s form DS-2032 as submitted […]
QUESTION: I am hoping you can advise on how to handle a repair and return export that should have qualified for and exemption but was inadvertently sent out on an export license? The license is for the same part, customer but different PO, and will now throw off our quantities for the current PO. Any […]
QUESTION: 1. Are capacitors that are clearly designed for commercial applications can meet the criteria of ITAR USML Category XI(c)(5), or only capacitors that are specially designed for military applications are controlled under ITAR USML Category XI(c)(5)? This is asked even that ITAR USML Category XI(c)(5) have only technical parameters and not the “specially designed”. […]
QUESTION: We sold ITAR controlled unit X to a foreign military, licensed – all good. The foreign military needs repairs done on that item. The repairs are on EAR99 parts of that unit X. They (the foreign military) are looking for replacement parts so they can do the repair. They put the repair out to […]