The State Department’s Directorate of Defense Trade Controls (DDTC) is cracking down on certain compliance requirements and violations involving software and technical data.

The DDTC is enforcing a consent agreement requirement which “forces companies to review and verify the jurisdiction and classification status of all hardware and software relating to their International Traffic in Arms Regulations (ITAR)-regulated activities.” From a recent settlement it appears that firms now must complete these reviews within one year, a much faster timeframe than they previously had. The completion of this review can also “lead to the discovery of other misclassifications and potential ITAR violations.” 

“It is crucial for companies to ensure the appropriate export jurisdiction and classification of their terms.” To achieve it may be necessary to complete “continuous reviews of company development and production changes as well as regulatory revisions.” It is crucial to have the necessary expertise when completing these reviews to guarantee that they are well documented.

Our advisors are happy to provide this expertise and assist you through filling out these reviews. Reach out to Mohawk Global Trade Advisors.

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