February 4th, 2013
Defense Article Manufacturers and Suppliers: Using the Cloud
The National Institute of Standards and Technology states that cloud computing is “a computing capability that provides an abstraction between the computing resource and its underlying technical architecture (e.g., servers, storage, and networks), enabling convenient, on-demand network access to a shared pool of configurable computing resources that can be rapidly provisioned and released with minimal management effort or service provider interaction.”
So, for the DDTC Registered organizations who claim they operate using compliant processes, I have a question or two.
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December 10th, 2012
No! DDTC Registration is not required for every organization
It seems to be all the new rave, supplier surveys now asking “Are you DDTC Registered?” Fabrication organizations need to understand that not all fabricators need to be DDTC registered.
December 3rd, 2012
ITAR (DDTC) Registration is NOT certification
Registration with the DDTC is primarily to provide information to the USG on those manufacturing and organizations involved with exporting Defense Articles.
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November 26th, 2012
How to use the various U.S. Government Lists
Some organizations get a little confused as to why there are so many different lists to check when participating in an EAR or ITAR transactions. Though the following is not an exhaustive list, it does however provide the newbie to defense trade controls a quick overview.
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November 12th, 2012
Are you sure your organization is ITAR compliant?
Cliff Burns at ExportLawBlog often discusses the shameless displays of organizations who mistakenly claim to be “ITAR Compliant”. We wholeheartedly agree with Mr. Burns’s comments on the subject.
In fact, we want to analyze organizationly capabilities a little deeper, specifically those organizations who are registered for AS9100 Revision C.
October 15th, 2012
SCB Training Center, Inc. to offer Advanced Compliance Officer course
SCB Training Center Inc. is pleased to announce that our Advanced Compliance Officer course will be offered through a local California University Extension Program starting Spring 2013.
October 15th, 2012
Common Mistakes Found When Preparing a DSP-5 Application
When your organization is requested to participate in an export transaction, it is your responsibility to ensure that all parties to the transaction are eligible to engage in exporting. This includes identifying all organizations involved in the manufacturing processm including minor components and parts. So when completing a DSP-5 application, pay close attention to Block 15 Manufacturer of Commodity. According to the DDTC the applicant must seek to determine when the source of the commodity is a manufacturer, that the manufacturer is registered with the DDTC, and also listing all sub-tier manufacturing suppliers, including special process suppliers.
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October 12th, 2012
Aerospace Supply Chain Warning!
Do your homework, know the end-use and end-user involved the transaction, otherwise you and your organization may receive a charging letter citing Part 764 of Title 15.
Often we hear excuses from the aerospace supply chain about why they think it is not their responsibility to perform reasonable care and due-diligence: “the customer never told us”, or “that is the Prime’s responsibility” or even “we have been in business for 20 years without a problem”.
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October 1st, 2012
Using an ITAR Exemption, Part 3
The procedure for returning the inspected part:
- Perform a customer Screening of the Denied Parties and other U.S.G. Agency lists
- Prepare the export documentation. When a defense article is exported, whether under a license, and agreement, or an exemption, the bill of lading and invoice must bear the following statement:
September 13th, 2012
Using an ITAR Exemption, continued
We have determined that this transaction will involve inspection only and will not require the exporting of technical data. The denied parties screening was clear. Based on this information the organization will use the following license exemption.
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