The State Department’s Directorate of Defense Trade Controls published recently guidelines on the elements of effective defense trade compliance programs and how to design and implement such programs for organizations that manufacture, export, broker, or temporarily import defense articles and defense services described on the U.S. Munitions List. DDTC states that the purpose of such compliance programs is to establish robust policies and procedures to ensure that organizations and their staffs who engage in activities controlled under the International Traffic in Arms Regulations do so in compliance with the ITAR and the Arms Export Control Act.

The guidelines address the following topics.

- company management commitment

- DDTC registration, jurisdiction, and classification authorizations

- recordkeeping

- detecting, reporting, and disclosing violations

- ITAR training

- risk assessment

- audits and compliance monitoring

- export compliance manual and templates

According to DDTC, the elements in these guidelines provide a foundation for the basic structure and function of an ITAR compliance program and are not intended to be exhaustive. The scope of ITAR activities in which different organizations engage varies substantially, DDTC states, so compliance programs should be tailored to address each organization’s ITAR-controlled activities, risk factors, and size.

DDTC adds that many organizations engage in activities that fall under the jurisdiction of multiple U.S. trade laws and regulations and that they should therefore ensure that their ITAR compliance programs function effectively within the context of a holistic export trade compliance program.

For more information on developing and implementing effective export compliance programs, please contact Kristine Pirnia at (202) 730-4964 or via email.

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