How to set up an ITAR-compliance program

1. Having management issue a policy indicating the importance of compliance and the consequences of non-compliance.

2. Establish a human reporting structure–who will handle what aspects of compliance?

3. Register with the State Department and make sure you keep your registration current.

4. Classify all known products and services, and set up a system for classifying new products.

5. Set up a system for ensuring products and services subject to the ITAR cannot be exported without a license, and bring business development into that process to ensure that proposals to sell defense articles are not made unless any approvals necessary are also obtained.

6. Establish a system for identifying ITAR-controlled technical data and a control plan for controlling it: a) in hard copy; b) in soft copy on computers, LANs, e-mail messages, etc. (involve your information technology department for this); c) by business travel; and d) by visits and meetings.

7. Involve human resources so that any licenses can be obtained for foreign nationals.

8. Involve procurement to ensure that ITAR parts are not procured abroad without ITAR review and licenses, if required.

9. Put in place record keeping procedures and reporting procedures.

10. Train employees on all of the above systems.

11. Audit all of the above systems.