ITAR/EAR Implementation - Aerospace Company with no Design Responsibilities

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Eloy Gomez

Not sure if I posted in the right place.

We are trying to implement ITAR and EAR requirements throughtout the organization including flow down requirements to our sub-tiers. As well better protection of our customer technical data. We are an aerospace company with no design and we built to print.

I would like to have a couple of ideas on how to implement this type of EAR/ITAR program. Or what would customers look for?

Thanks in advance.
 
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MarkSCBTCI

Eloy, Good question. Customers typically want to make sure that the supply chain has a thorough understanding of the various requirements to prevent inadvertent violations with the ITAR or EAR.

There are several other areas that should be included (beyond what I list here) for a compliance program to be considered "best practices", but generally for ITAR compliance I look for: 1. That they understand the regulations, that an informed and knowledgeable Empower Official has been appointed, 2. They understand how to classify the item (Hardware, Technology and Technical Data) in order that they know which rules apply, 3. They screen for denied parties and etc., 4. They have the processes in place for obtaining, executing and closing licenses (including understanding the provisos) and a procedure for filing a VD, and lastly 5. They have identified and maintain all of the required export control records. For EAR I expect them to: 1. Have an understand what "subject to the EAR" actually means, 2. They know how to use the CCL and Country Control Chart, 3. Can tell me the 10 general prohibitions, and 4. Have solid export clearance procedures in place.

After all that is said, implementing an export compliance manual and technology control plan is vital.
 
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