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