ITAR & Export Compliance Program Implementation
CVG Strategy ITAR & Export Compliance Program
Multiple Compliance Requirements for Export of Goods
CVG Strategy provides ITAR and Export Compliance Programs in a format that are more easily implementable for businesses of any size. This is accomplished through a harmonized approach to the various sets of regulations that U.S. businesses must comply with when exporting products, services, and technical data.
Export compliance regulations are complex and required detailed analysis to ensure compliance. Two major regulations are the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations.
International Traffic in Arms Regulations (ITAR)
The ITAR pertains to articles that are developed or specially designed for military applications. These goods are categorized in the United States Munitions List (USML). The ITAR is administered by the Directorate of Defense Trade Controls (DDTC).
Export Administration Regulations (EAR)
The Export Administration Regulations pertain to items not listed under the USML. These goods are categorized under the Commerce Control List (CCL). The EAR is administered by the Bureau of Industry and Security (BIS).
Required Elements of a Viable Compliance Program
Both the DDTC and BIS has specific requirements for an Export Compliance Program. These requirements are shown in the table below. Failure to implement and administer an effective export compliance fine can result in fines, debarment (loss of ability to export products) and imprisonment. Therefore it is crucial to have a program that meets all requirements.
Additional Export Requirements
While ITAR and EAR are the primary regulatory requirements, businesses must also comply with the following as well when conducting exports:
- Antiboycott Regulations per the Department of Commerce’s Office of Anti-Boycott Control (OAC)
- U.S. Department of the Treasury’s Internal Revenue Service (IRS)
- U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC)
CVG Strategy Export Compliance Solutions
While many export compliance providers offer programs geared toward compliance with a single set of regulations, CVG Strategy offers a harmonized program that will ensure that your company is compliant to all of these regulations. Furthermore we consolidate this program in a collection of documents that can be integrated into a quality management system.
Quality Management Approach to Export Compliance
An effective export compliance program must be integrated into all aspects of an organization. It must clearly define roles, establish policies, train all employees, and provide concise work instructions for the execution of required tasks. Furthermore it must undergo risk assessment and periodic auditing to identify potential shortcomings and incorporate corrective actions.
This makes an export compliance program an excellent choice for inclusion in a quality management frame work. CVG Strategy’s Export Compliance Management Program (ECM) Manual and associated documents are structured in accordance to ISO 9001 and AS9100D. They provide policies, a manual, work instructions, and forms for the completion of specific export compliance tasks.
Support in Program Implementation
CVG Strategy can provide support in the implementation of your program to ensure that the specific requirements of your business model are met. This ensures that the program will address all stakeholders and meet your regulatory and customer requirements.
Our training programs ensure that your export compliance team is up to date in their comprehension of export regulations. These engaging classes are available online on a regular basis. They provide ample time for your questions and specific concerns.
We can assist in export control classification of items against the United States Munitions List and the Commerce Control List. We also provide ITAR program assessments to enable your program to pass audits.
Continuing Support Available
Many customers rely on our continued support when faced with complex issues with export compliance. These can include difficult item classification issues or even guidance in voluntary self disclosure. We also provide quick answers for your ITAR questions on a question by question basis. Additionally, our ITAR Store can supply you with signs, visitor badges, and other accessories required for maintaining site security