ITAT compliance manual training control

EXPOSURE to ITAR Compliance failure is highly probable if you do not have an effective manual and adherence to the following factors.

Without management participation, reviews, training and monitoring = failure. 

Export (ship) – send abroad

Go abroad and release information – overseas speech

Allow access to product or information with foreign national – private conversation

Electronic transmission 

Factors to consider in a strong compliance system.

  1. Whether the company has performed a meaningful risk analysis.
  2. The existence of a formal written compliance program.
  3. Whether appropriate senior organizational officials are responsible for overseeing the export ITAR compliance program.
  4. Whether adequate training is provided to employees.
  5. Whether the company adequately screens its customers and transactions.
  6. Whether the company meets recordkeeping requirements.
  7. The existence and operation of an internal system for reporting export ITAR violations.
  8. The existence and result of internal/external reviews or audits.
  9. Whether remedial activity has been taken in response to export ITAR violations.

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