ITAR Consulting – Export Compliance Expertise
ITAR & Export Compliance is a specialty of CVG Strategy’s ITAR Consulting services.
You will find that CVG Strategy’s ITAR Consulting is different than many other consultant’s ITAR Consulting services. Our ITAR & Export Compliance Specialists have managed manufacturing and distribution businesses in the past, and we have worked for multi-national organizations. CVG Strategy’s experts are not ex-government employees. They are practical operations folks very familiar with the needs and goals of small to medium sized operations that are involved in international trade.
It is required that every one of our ITAR & Export Compliance Specialists take continuing education several times each year, and maintain their ECTI Accredited Export Compliance Professional-EAR® (EAR Export Controls) and ECTI Accredited Export Compliance Professional-ITAR® (ITAR Defense Trade Controls) certifications.
What is ITAR?
The International Traffic in Arms Regulations (ITAR) are the export laws pertaining to defense related materials and technologies, including hardware, software, and services. The goal of ITAR, which is administered by the (DDTC) Directorate of Defense Trade Controls, is to safeguard U.S. national security and further U.S. foreign policy objectives.
Under ITAR a company is required to register if it manufactures defense articles or provides defense services even if the product is never exported.
What are the requirements for ITAR Compliance?
- If required the organization must registered with the DDTC
- The organization must have a documented compliance policy with specific procedures for export activities.
- Any entity or party that a company engages with must be screened against a current denied parties watch list screening
- The export compliance program must conduct internal audits and continuous improvement.
- The program should also conduct third-party audits annually
What is the EAR?
The EAR (Export Administration Regulations) regulates and controls exports of goods from the United States. All goods and services that are not covered under the State Department’s US Munitions (USML) list fall within the preview of the EAR. These items are categorized under the Commerce Control List (CCL). The EAR is administered by the Bureau of Industry and Security.
The mission of the BIS is to protect U.S. national security, homeland security, foreign policy, and economic interests through a law enforcement program. This program focuses on sensitive exports to hostile entities or those that engage in arms proliferation. They also enforce prohibited foreign boycotts and related public safety laws.
Original authority was granted the BIS under the Export Administration Act of 1979. The International Emergency Economic Powers Act, as amended, with additional authority granted from a series of Presidential Executive Orders added to the legislative support for the Export Administration Regulations.
What about Anti-Boycott Regulations?
In the United States, anti-boycott regulations primarily deal with restrictive trade practices against Israeli businesses. The Arab League requires member countries to boycott trade with Israel and trade with companies that trade with Israel.
In response, the U.S implemented laws in the mid-1970s to prevent U.S. companies from boycotting trade with Israeli companies. The law also prohibits the refusal to employ U.S. citizens because of their nationality, race or religion.
The purpose of the regulations is to prohibit U.S. companies from implementing other countries’ foreign policies when those policies disagree with U.S. policy.
These laws as defined by the Export Administration Act (EAA) exact criminal and civil penalties (fines, imprisonment, and denial of export privileges) for companies and employees in non-compliance.
What does Export Compliance mean to businesses?
If your company deals with defense equipment, supplies, services or technologies, federal regulations specify that you share these items only with U.S. persons and organizations. To do otherwise requires authorization from the Department of State or qualification for a special exemption.
If your company offers dual-use or specially classified items under the control of the Commerce Control List (CCL) similar restrictions are applicable. Non compliant companies and individuals may face potentially heavy fines or penalties for providing foreign persons with access to ITAR or EAR-protected and restricted items.
ITAR Consulting at CVG Strategy
CVG Strategy, LLC is recognized the world over as the premier provider of customized export compliance programs. This includes ITAR and Export Administration Regulations (EAR). We also can provide assistance with the Canadian Goods Program.
Our ITAR compliance consultants work with businesses of all sizes. We have the compliance and training programs to fit your exact needs. We even serve as an outsourced Export Compliance Officer for some clients, who don’t have the bandwidth to dedicate to the function but need it done on a part-time basis.
How Can We Help?
Take a look around our site and contact us for more information on how we can help you meet your challenges.