I was looking to get some feedback on a ITAR question that has surfaced. Has anyone been through an audit mandated by the State Department? I understand that many audits are actually the result of self disclosures but I am trying to understand if the audit would consist of a complete scrub. For example, if […]
My company manufacturers some military spec electronics (Mil spec 883-B). Products can be used for either Military or Commercial (Dual-use). If not “specifically designed or modified” for military applications, only assembled to military spec, would the commodities be subject to ITAR?
Do you have to send the SED to ODTC when using exemption 22CFR 123.4(a)(1)? If so, does the SED need to be signed by customs or do you just send a copy of what was sent with the shipment? I see the requirements for customs, but I do not see the requirement for ODTC. In […]
How have other members handled provisos that are unclear? Have you used general correspondence or a DSP-6003 Request for Reconsideration of Unclassified Provisos? What is the average turn around time for this response from State? When do you involve outside counsel in this process ?
We are a US company that makes connectors which can be used in a variety of applications. We have a baseline connector product that is modified specifically for each and every individual application. Based on a strict interpretation of ITAR, therefore, modifications of our baseline product for military applications (i.e., applications on the US Munitions […]
Does anyone know what section within the ITAR and the U.S. EAR addresses in-transit shipments? We have a facility in Canada that ships defense articles to Latin America. They have been told that anything traveling through the U.S. will require a U.S. export license even if the plane is only stopping for refueling. The same […]
We are potentially going to receive some ITAR reloated materials from a potential customer in the UK. WE will have an NDA signed in advance. In order to quote on thre business, we will receive som drawings, technical data, etc.. Can we import this under a temporay bond, and re-export to orgin without filing for […]
Question: We have a contract with the government to work on ITAR related items. The government has transferred data (software source code) to us for that contract. We need to obtain a DSP-5 for one of our foreign nationals working on this contract. Is the government responsible for obtaining the TAA with our employee because […]
How are molds, tooling, fixtures used in the production of ITAR items treated? They do not seem to meet the 120.3 “…for military APPLICATION” definition, since these items themselves are not for military application, but rather used in the production of finished defense articles. Generally the mold/tooling/fixtures is for a specific part, so if it […]
How are molds, tooling, fixtures used in the production of ITAR items treated? They do not seem to meet the 120.3 “…for military APPLICATION” definition, since these items themselves are not for military application, but rather used in the production of finished defense articles. Generally the mold/tooling/fixtures is for a specific part, so if it […]
Question: I’m trying to import something using 22 CFR 123.4(a)(1) exemption for temporary import of defense articles. The (courier) broker has no idea what to do. I told her to note the exemption on the entry. She’s clueless. Called another broker who said we don’t need to note it on the entry (WRONG!!). Does anyone […]
Does anyone have an outline of a basic MLA they would be willing to share? (specific to ITAR)
