The State Department’s Directorate of Defense Trade Controls (DDTC) has released its long-awaited updated compliance program guidelines which are intended to outline and detail “key el­ements” of an effective compliance program, the agency said. The guidelines include the following:

  • Management Commitment
  • DDTC Registration, Jurisdiction and Classification, Authorizations, and Other ITAR Activities
  • Recordkeeping
  • Reporting and Addressing Violations
  • International Traffic in Arms Regulations (ITAR) Training
  • Risk assessment
  • Audits and Compliance Monitoring
  • Export Compliance Manual and Templates

These guidelines emphasize that commitment from management is “one of the most important factors in creating a deep-rooted culture of ITAR compliance within organizations,” the agency said. With commitment at the highest level in an organization, it can be the key to ensuring a successful implementation of each company’s policies and procedures.

The guidelines also mention that organizations should screen all parties in an ITAR-related transaction before doing business with them, and cross-reference them against the government’s Consolidated Screening List, which includes sanctions implemented across the State, Treasury, and Commerce departments.

Organizations should also have an ITAR compliance manual, which provides “all employees with a written, authoritative source that sets forth the organization’s policies and procedures for ITAR com­pliance,” DDTC said.

For more information on DDTC new compliance program guidelines or need assistance developing an ITAR compliance manual? Reach out to Mohawk Global Trade Advisors.

By Clarissa Chiclana

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