Russ Farmer, one of ReliAscent's co-founders, passed along a very interesting piece of news to me this morning, written by Jim Harris of the Holland & Knight Law Firm. It seems a California-based, small business aerospace contractor was eliminated from an ARMY Contract Competition last month, simply over the "description of its own ITAR compliance program." Naturally, this piece caught my eye---as that second sentence may have just caught yours (and the attention of the thousands of government contractors that regularly read our blog).Read More
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In our last blog we discussed the export regulations for commercial items. Many government contractors also have an obligation to control export of data and goods outside the United States under the Arms Export Control Act (AECA) or the International Traffic in Arms Regulations (ITAR). These regulations are designed to protect our military technology and advantage and can be a much more serious issue. The AECA governs exports (both permanent and temporary) of both defense articles (products and data) as well as defense services. The ITAR controls export of technology as defined in the US Munitions List (USML). I’m sure many of you have seen documents that have had ITAR control stamps on them. I think it is interesting to note that ITAR controlled items could be a violation without the item ever leaving the country. This would be a case where a foreign person sees or has access to ITAR controlled information/products in the US. I had an experience one time where I was in a meeting at a large defense contractor and an engineer from Canada was escorted out of the meeting by company security as the discussion turned to ITAR controlled information.
Many government contractors are subject to the International Traffic in Arms Regulations (ITAR) but may not realize the implications of these regulations. Some people are under the impression that the regulation only applies to the export of products outside the United States. The regulations, in fact, also cover technical data and software. This includes not only design data but covers training manuals, classified information, consulting, engineering, technical services and data. The regulations also cover this information even if it does not leave the United States physically. For instance, if a foreign visitor in a US facility is exposed to covered items, or an oral description to a foreign person would constitute a violation of the regulations. Violation of the ITAR regulations can result in stiff penalties, including: