Understanding ITAR Training

• Register with the U.S. State Department’s Directorate of Defense Trade Controls. There is a non-refundable fee associated with registration.
• Obtain the proper licenses for the things you plan to export.
• Ensure your policies and procedures are compliant with ITAR requirements.
• Make sure someone at your facility is educated about ITAR and trained in how to keep your policies and procedures compliant.

That little bullet point about making sure your policies and procedures are compliant with ITAR requirements… that means you must have those policies and procedures in place, your staff trained, and be able to prove to an assessor that you do have an ITAR & EAR program in place and are not being negligent in your handling of this sensitive information. There is a lot to that!

ITAR Certification is a misnomer; you cannot gain an ITAR Certification like you can an ISO Certification or a CMMI rating. There isn’t a specific standard or set of criteria to be rated against to achieve “ITAR Certification.” Of course, you can include your ITAR Compliance program in the ISO Certification and auditing process but that’s not going to prove you are following the ITAR regulations; it will only demonstrate that your Company is following the Company’s policy, procedures and work instructions consistently.

Companies must understand that while the ITAR specifically calls out “arms”, it covers literally anything that could be used in defense to include training. Furthermore, the ITAR does not only apply to goods sold overseas, ITAR also covers technology that is placed on websites, training given in the US and goods sold in the US destined for an overseas location. Many companies have found themselves on the wrong side of the ITAR because they “thought” it didn’t apply. Fines and penalties for infringement of the ITAR are not insignificant and can easily destroy a company, however even more significant is the fact that USDOS goes after individuals as well as companies, so the issue may not subside when a business is closed, meaning that USDOS will press civil and criminal suits against specific individuals within the company as well as the company itself.

US companies must educate themselves and establish practices and procedures to address and mitigate the issues contained within the ITAR in order to be considered compliant. The good news is that On Call Compliance Solutions has a complete solution to help you quickly and easily implement these programs and prove that you are correctly handling this sensitive protected information the right way.