Visitor Badges for ITAR Compliance
Visitor Badges for Site Security
ITAR Visitor Badges are an essential part of a visitor management system. They protect controlled information by limiting access to those parties who visit your facility. This is important because release of this information to foreign persons is considered a deemed export under U.S. export law.
U.S. Export Compliance
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).
Violations of export compliance regulations can result in both civil and criminal penalties. This includes fines, imprisonment and debarment (loss of legal right to export goods and services.
Organizations often unknowingly will be non-compliant to export regulations. When this occurs the organization will often file a voluntary disclosure. As part of a resulting investigation, the applicable enforcement agency will look for signs of a viable compliance program. The visitor management system is part of the program that will often be inspected.
When a healthy compliance program is found to be in place, and adequate steps have been taken by the organization to ensure that future violations will not be likely the enforcement agency will generally act with greater leniency.
The History of ITAR
The Arms Export Control Act (AECA) and ITAR were implemented during the cold war to establish unilateral arms control. These controls have continued to change, and the rate of enforcement activity has dramatically increased. The U.S. Munitions List also undergoes changes in response to the development of new technologies and changes in the international political arena. For example, until 1996–1997, ITAR classified strong cryptography as arms, and prohibited their export from the U.S.
When you have visitors at your facility, it is important that you restrict access to individuals who do not have the legal authority to view or interact with restricted articles including your company’s products or services. It is a “deemed export violation” if a foreign citizen were to visit your company and see an ITAR Product being built.
It is therefore important to have effective visitor management processes for your facility to control visitor access and to ensure that your employees know how they may interact with the visitor. Using ITAR visitor badges ensures that your visitor is properly identified so that the controls and protocols you have in place ensure proper handling of their visit and reduces the risk for a violation.
Your visitor badges should have one for citizens of foreign corporations or foreign citizens. Another for U.S. Persons with Escort Required and one for U.S. Persons No Escort Required.
Find out more about ITAR compliance and whether your company should be registered by contacting CVG Strategy, experts in ITAR and Export Compliance, for a consultation.
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