Security Executive Blog

A few years ago I facilitated a short but very rewarding eight hour seminar on the International Traffic In Arms Regulation (ITAR) Overview. I am grateful to the staff at the University of Alabama in Huntsville and the North Alabama Trade Association for both sponsoring the event and allowing me to present. I found the course rewarding as I presented to a mixed audience of 30 professionals ranging from shipping and receiving specialists to executive vice presidents. The mix also consisted of professionals with various degrees of know-how as consultants, attorneys, technology control officers and those brand new to the field shared experiences and learned from one another. As a compliance officer in various disciplines, I have had the privilege of leading security and compliance teams and seminars on multiple topics Though this was my first of hopefully many export regulations seminars, I noticed the similar need in the compliance field. Regardless of the discipline, compliance works b...

Several years ago I became aware of a situation where a defense contractor’s export compliance officer was approached by a business development manager about an opportunity. The business manager stated that the company was pursuing a contract with a foreign country to sell them an export regulated material. Though the material was clearly designed for military use, the business manager rationalized that the application was for civil and not military use. She rationalized that since the transaction would not be for defense application, the company should not need to seek an export license. Though there is guidance for what and how to export, many export issues are unique and may not be fully understood, until the export compliance officer asks the right questions and gets the full story. It’s not the intent of the transaction, but the technology, product or item being transferred. Recently a company was fined for violating an export law by shipping a controlled chemical. In an...

ITAR Though not as sinister and espionage riddled as most savvy spy novels, export compliance is an issue that will get Defense contractors in trouble. Violating State Department regulations will bring the weight of the US Government on the offending company. According to the International Traffic In Arms Regulation, ITAR , “Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register”. Cleared contractors must have a plan not only to protect classified information, but also to prevent the unauthorized transfer of technical information and data." Unauthorized transfer of technical data can occur in a variety of ways. Keep in mind that exports can and do occur not only during shipments but when hosting foreign visitors, during meetings, trade shows, plant tours, chat-room discussions, published articles and many other means. You can even export technical items exposed on...