Why do I need a compliance program?

Per the Directorate of Defense Trade Controls (DDTC):

The Office of Defense Trade Controls Compliance strongly advises parties engaged in defense trade to establish and maintain an ITAR/export compliance program. We rely on everyone who deals with USML items to help us protect our nation’s sensitive technologies.

In designing a compliance program you need to understand how your business works to determine your risk areas. Possessing defense articles or technical data raises your risk of an inadvertent violation. Many companies that don’t engage in manufacturing, exporting, or brokering, still maintain compliance programs to reduce the risk of such violations.

A good program is generally:

• Clearly documented in writing
• Tailored to the business
• Regularly reviewed/updated
• Fully supported by management

Where do I start?

The Directorate of Defense Trade Controls (DDTC) is responsible for ensuring that commercial exports of defense articles and defense services advance U.S. national security and foreign policy objectives.

It is comprised of three offices:

• Defense Trade Controls Policy (DTCP)
• Defense Trade Controls Licensing (DTCL)
• Defense Trade Controls Compliance (DTCC)

What are the regulations?

The Department of State is responsible for the export and temporary import of defense articles and services governed by 22 U.S.C. 2778 of the Arms Export Control Act (AECA) and Executive Order 13637. The International Traffic in Arms Regulations ("ITAR," 22 CFR 120-130) implements the AECA.

Those regulations are available in the Federal Register, or you can view an abridged version at on the DDTC web site.

DDTC Organization