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Showing posts with the label export

Redefining an Export and Reducing Export Violations; An FSO's Opportunity

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Order your copies from www.redbikepublishing.com /itar A few years back I wrote an article referring to the practice random computer searches occurring as travelers returned to the United States from trips abroad. Now with technology improvements, time, and the shrinking of borders in this well-connected global economy, I thought it would be a great time to revisit the idea of, “what would an adversary with limited resources be able to exploit in our computers?” This is an important question to ask as cyber-attacks are becoming more common. Now an adversary on foreign lands can gather military or dual use technical information governed by the international Traffic in Arms Regulation (ITAR) and commercial information covered in the Export Administration Regulations (EAR). This cyber-attack activity should not be surprising to the well-educated security cleared employee. What may be surprising is the risk to protected sensitive information available on well-connected informatio...

New ITAR Guidelines

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The unofficial ITAR has been updated. The three affected parts are: Part 120, Part 123 and Part 126. Some of the changes include paragraphs that were formerly categorized as "reserved". The changes equal 20 additional pages to a 5 x 6 book publication of the ITAR. That's pretty significant. In fact Part 126.16 is such a paragraph formerly marked as "reserved" and now is filled with 5500 words of text. Let's take a look at the exemption to the Defense Trade Cooperation Treaty between the United States and Australia. This paragraph defines transfer, export, retransfer, reexport, Australian Community, United States Community and other relevant terms. It also explains which exports qualify for licensing exemptions. Though the information addresses transfer of export controlled items between the US and Australia, this article is written to  provide a rule of thumb in handling all cases of export controlled information, articles and services. Paragrap...

marcus evans ITAR Compliance WEST Conference

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Executives from the Aerospace, Defense, Satellite and Similar Industries to Share Best Practices and Lessons Learned at the marcus evans ITAR Compliance WEST Conference  Navigating the Complexities of the Changing Compliance Structure through Improved Operational Communication, Language Interpretation and Jurisdictional Understanding  San Diego, CA– September 27, 2013– marcus evans, the world’s largest event management group, will host the ITAR Compliance WEST Conference, November 18-20, 2013 in San Diego, CA. Executives across the Aerospace, Defense, Satellite and similar industries will share their thoughts and practices for compliance with the ever-evolving export regulations. DRS Technologies, Raytheon, Northrop Grumman, Virgin Galactic, Lockheed Martin Space Systems Company, Maxim Integrated and many other will be discussing their challenges and efforts with past and future upcoming reforms efforts. October 15, 2013, new rules are expected to go into effect changi...

ITAR Free? ITAR light? Export Reform

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Get your copy at  www.redbikepublishing.com Export Reform Update, Panel Remarks to the U.S. Department of Commerce Bureau of Industry and Security Update Conference, were given on July 24, 2013. These remarks hi-lighted the export compliance communities concerns with present day policies. In the remarks current polices were addressed as "onerous" and "confusing" reflecting consumer and customer expression and experience. To address the communities, a task force was convened to focus on four areas: * Licensing policies and procedures * Control lists * Information technology * Export enforcement In an effort to clarify licensing policies and procedures and to work the 80k license requests per year, the task force focused on reform in three phases. The first phase is complete as the task force addressed the munitions lists, recalibrated and harmonized definitions and regulations, updated licensing procedures, created an Export Enforcement Co...

Eliminate Export Violations

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ITAR is here Export compliance first and foremost helps companies and individuals successfully earn profits while playing by the rules. Our government encourages international business. The opportunities for expanding business and growing employee experience make international trade an attractive endeavor. The benefits are huge as long as enterprises know the rules and successfully transfer technology. The reality is that a license or technical assistance agreement may many times be possible and likely be granted when given the time and consideration required.  Unfortunately, the routes professionals sometimes take to avoid licenses causes export violations and significant damage to our defense and economy. Successful export occurs where the whole team understands the mission and each business unit and employee role. The compliance officer trains the company and keeps the empowered official abreast on licensing and technical assistance issues. They also establish trigger me...

Putting it all together-The Impact of the Influential FSO

FSOs should understand more than just the technical aspects of administering a security program.  Understanding how to mark, safeguard and disseminate classified information is important. However, the FSO should reach beyond the description of implementing a security program to safeguard classified material. The position also requires: 1.  Assessing risks to the classified material 2.  Interpreting safeguarding requirements 3.  Communicating and incorporating a culture of compliance within the organization 4.  Projecting the impact of classified contracts on the enterprise. To do this, the FSO should possess the vision and skills to see where the security program needs to go, how to get there and encourage a security vision from the senior executive level downward. Without the proper influence, the FSO is may not be able to run a program to protect classified material Effective tools include: • Helping form...

4 Measures to Prevent Unauthorized Export of Technical Data

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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...

How Defense Contractors Protect Technology - Applying NISPOM and ITAR

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Red Bike Publishing's ITAR Defense Contractors providing defense items or services have the tremendous responsibility of keeping the technology out of the wrong hands. As identified in the ITAR, unauthorized release of technical information can affect the US military's fighting capability. Licenses and agreements provide a checks and balances between the US Government and the US Company desiring to export the technology. The company identifies the technology and application and submits export requests to the State Department. The State Department reviews the application and further researches military application and how the export could affect national defense. Without such checks and balances, other countries could gain a technological advantage. Consider the GPS and night vision technology. No other nation has the abilities as the US does to operate at all times and in all weather. The US military's technological lead creates the ability to determine, where, when an...