May 19th, 2012
Merely testing items also triggers export control requirements
For the uninformed, it’s easy to think that actions that don’t involve the export of goods can’t trigger ITAR requirements. But the requirements can go beyond that. 122.1(a) of the regulations means it takes much less than an actual export to run afoul of the law.
May 12th, 2012
Failing to make voluntary disclosures of ITAR violations is a mistake
Alpine Aerospace of New Jersey got itself into some hot water with the State Department for violating the Arms Export Control Act and the ITAR. TS Trade Tech did as well. One firm was punished more harshly than the other. Guess why?
May 5th, 2012
NASA Ames head violates ITAR
While the Navy can get away with ignoring OFAC, NASA’s Ames Research Center is in trouble as Simon ‘Pete’ Worden is accused of breaking export regulations.
April 30th, 2012
Evading sanctions on Iran is serious business
We previously covered the US Navy ignoring OFAC regulations enforcing economic sanctions against Iran. Private firms are advised not to follow suit. To attempt evasion is a costly mistake.
April 20th, 2012
Obey the FCPA: Avoid corruption abroad
Corruption is a serious impediment to economic growth and prosperity. That’s why the United States does more than just fight corruption at home. We additionally ban Americans from planning and carrying out bribes of foreign officials.
This prevents importing corrupt practices from abroad. It’s never just the cost of doing business. Know the law.
April 14th, 2012
America must avoid budget sequestration
Under the terms of a deal passed by President Obama and the Congress, Over half a trillion dollars of defense spending will be cut under a process being called “sequestration.”
According to the AIA, this would increase unemployment by a full point as it destroys over a million jobs. It would also open us up to threats at home and abroad, as our defense abilities are eroded.
April 9th, 2012
US Navy to rescue ship on OFAC blocked list
The Office of Foreign Assets Control (OFAC) maintains a list of Specially Designated Nationals and Blocked Persons. As the Treasury Department says, “Their assets are blocked and U.S. persons are generally prohibited from dealing with them.”
However the US Navy plays by its own set of rules.
March 31st, 2012
Is your goal AS9100 compliance? Then study ITAR.
AS9100 compliance is critical to many aerospace manufacturers. In the 12 years since the standard was first issued, it has become an established set of requirements in the industry.
And yet, some look for any reason to get around the ITAR requirements. That’s a mistake for any organization claim AS9100 compliance.
March 23rd, 2012
Evading ITAR requirements is a criminal offense
ITAR has a broad definition of a violation. Under the authority of the Arms Export Control Act (AECA), the Office of Defense Trade Controls, Section 127.1 of the ITAR states that “No person may willfully cause, or aid, abet, counsel, demand, induce, procure or permit the commission of any act prohibited by, or the omission of any act required by 22 U.S.C. 2778, 22 U.S.C. 2779, or any regulation, license, approval, or order issued thereunder.”
As a result, individuals, not just their employers, are at risk of civil and criminal penalties under AECA and ITAR.
March 16th, 2012
President Obama’s Executive Order complicates export control
President Barack Obama set out laudable goals for export control in Executive Order 13558, but unfortunately the execution achieved the oppposite effects. He complicated and overtaxed the lines of communication in government.