October 30th, 2011
An ITAR Record Keeping Procedure
§122.5 states the requirements for registrants to maintain records. Quality management system developers would be doing their organizations a big favor if they read and understood this requirement, especially where the term “related documents” is used.
Most ISO quality manuals fail to capture and list all of the required documents needed to satisfy the ITAR.
There are over 50 occurrences of the word “records” and/or “recordkeeping” in the ITAR §120-130. The following is a sample of the ITAR records that should be maintained for a minimum of five years of the date of the transaction:
- Contracts and Quotes
- Customer Questionnaire (End Use and End User Statements)
- Shipping and Receiving Documents (i.e., Airway bill, Bill of lading, Commercial invoices, etc.)
- Certificates of Conformance/Test Reports/Consultation Reports & White Papers
- Specifications and drawings
- Long Term Agreements, TAAs and DSP Applications
- Any DDTC Correspondence
- Customer correspondence (Paper and Electronic)
- Denied Party Screening Results
- Personnel ITAR Training Records
- Visitor Records
- Documented approvals by the Empowered Official, Chair Export Compliance Council for all export control documents and actions (i.e., Emails, Memorandums, etc.)