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, […]
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) […]
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 […]
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- […]
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 […]
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 […]
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 […]
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. […]
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. […]
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 […]
QUESTION: My company hasn’t been involved with ITAR issues until we recently acquired another company. Currently our IT infrastructures remain separate, but in anticipation of migration (in small bites, over time) to a combined infrastructure, we are trying to assess the IT-related risks we must address. Does anyone have any benchmark risk guidance on the […]
QUESTION: We are a foreign entity located in Mexico and manufacture EAR600 as well as ITAR goods, the US customer does have a BIS license as well as DDTC licenses in place and we are listed on these licenses. My question is: if the foreign Mexican entity sends tech. data to a US supplier for further […]
