http://www.exportimportcompliance.com/controls-training.php
WE can train you in import export procedures (company).
|
http://www.exportimportcompliance.com/controls-training.php
WE can train you in import export procedures (company).
|
FLIR case
ITAR Compliance Program failure (s)
Significant compliance program and internal control deficiencies that directly contributed to the violations.
Deficient ITAR expertise and senior leader oversight during violation period.
Failure to effectively investigate and discover uncover and disclose violations.
Frequency and repetitive nature of same violations.
Failure to implement remedial compliance measures represented to the department.
Need to have an effective compliance program and effective administration including review.
Avoid penalties ($30,000,000) and controls by having effective control.
Factors to consider in a strong compliance system.
https://www.sbir.gov/tutorials/itar/tutorial-1#
ITAR compliance risks
Unauthorized exports included the transfer of technical data
Significant improvements to its export compliance program that reduce the likelihood of future violations, including conducting internal and independent audits, conducting staff training on the ITAR (including more extensive training for personnel directly involved in export compliance), creating a fully documented compliance program (with formal procedures, checklists, and a compliance manual), and significantly increasing staff resources devoted to day-to-day compliance (including retaining an outside consultant to provide expert advice where needed). These steps were taken after the fact and should have been in place to prevent.
Posting drawings on website or sending to foreign supplier for quote can constitute an export without a license and bring penalties. Bright Lights USA
https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=715d7289db99db0044f9ff621f961939
training tutorial
https://www.sbir.gov/tutorials/itar/tutorial-1#