ITAR

ITAR

  • MANAGING USML ITEMS IN THE UK

    QUESTION: Our U.S. designed products are sold out of the U.S. and the U.K.  In accordance with U.S. Export Control Reform, we have reclassified many of our formerly ITAR controlled products to EAR control.  Some have transitioned to 600-series ECCN’s and some have transitioned even to a less-restrictive ECCN.  Some dual use products were already […]

  • Technology Control Plan for Non-Employees

    QUESTION: One of our ITAR/EAR-controlled facilities is sharing office space with a sister company foreign national employees. The employees have access to our facility and share our break room and restroom areas. There is no outside entrance upstairs, so the employees have to access yellow line only areas to get to there work area. What […]

  • POTENTIAL RUSSIA DISTRIBUTOR

    QUESTION: We have a current customer that wants to be a Distributor is Russia. Since Russia has many sanctioned individuals, I want to ensure we are in compliance and have done our due diligence . The items they will be purchasing are not controlled under EAR or ITAR.   We screen all our customers, vendors, […]

  • CLASSIFYING CABLE IN USML

    QUESTION: I have to classify a “Specially Designed” cable that on the one side connected to ITAR’s USML system,controlled by USML CAT-IV(h)(9), and on the other side this cable is connected to a system that is under,EAR’s CCL ECCN 9A604.x.,,Does this cable is indeed controlled under ITAR’s USML CAT-IV(h)(9), or can I apply the 120.41(b)(3) […]

  • ITAR RECORDKEEPING

    QUESTION: We are setting up electronic recordkeeping and need to understand if shipping documents (shipping or commercial  invoice) of an ITAR product would be ITAR controlled and must be kept segregated from non-US persons ? ================== ANSWERS: No, as long as there is no export controlled technical information on the shipping documents (which there shouldn’t […]

  • ITAR CLOUD STORAGE

    QUESTION: Does anyone know of specific cyber security- cloud storage requirements (regulations) for ITAR Data?   Other than the known encryption best practices – is there for example – a requirement whereby if data is stored in a cloud based service – the owner is required to have the keys? (Best practice would be yes- […]

  • SAMPLE ITAR NOTICE

    QUESTION: Some of our engineers will be evaluating ITAR-controlled technology over a period of time. I want to give them an €œITAR Notice€ that can be read before the start of any meeting regarding the evaluation and have the participants sign a statement of confidentiality specific to this technology prior to access. Because we don€™t […]

  • PART CCL LIST SCENARIO

    QUESTION: I found out that equipment that my product is used in as an “attachment” is on the CCL Alphabetical Control List and has an ECCN number but my product is not on the Alphabetical Control List. While I do not see the name of my product on the Alphabetical Control List  would it be […]

  • ITAR SCRAP PROCESS

    QUESTION: We have historically dealt primarily with ITAR controlled hardware.  When our foreign parent needed to scrap damaged hardware no longer useable, we submitted a General Correspondence (GC) on their behalf to allow them to scrap the material.   We now have many situations where the hardware has transitioned to 600 series ECCN from CAT […]

  • ITAR DUAL CITIZEN EMPLOYEE

    QUESTION: Does an employee in a U.S. corporation who holds dual citizenship (U.S. and Israel) need a license to work with ITAR-controlled products? Or, is this employee is a citizen regardless and NLR? ************** Answers: Once a person becomes a US citizen, no licenses are required. However It is not the same for permanent residents. […]

  • HIRING PROCESS FOR FOREIGN ITAR

    QUESTION: I am working with senior leaders in our company to establish an HR policy on hiring of foreign persons. The company has recently consolidated a number of separate entities under a single company here in the US. We are incorporated in the US, but foreign owned and ITAR registered as a manufacturer / exporter. […]

  • USML POINT OF CONTACT

    QUESTION: In the regulations for the United States Munitions List that one dedicated individual must be named as POC or can it be multiple contacts? ========== Answers: Of course it can be multiple contacts – we have about 30 Empowered Officials at our company – we are huge! ========== “POC” is an ambiguous term in […]