Department of the treasury office of foreign assets. The manual applies to the ku community, including its faculty, staff, students. The purpose of cornell universitys export control compliance manual is to provide the basis for the operational program and procedures which manage export decisions and transactions in compliance. The ocecc oversees export controls and trade sanctions compliance for the campus and, with implementing departments, it develops and monitors procedures and record keeping systems to. Export control laws and regulations, to identify key export compliance issues related to research. This publication of the international traffic in arms regulations itar is intended to be a convenient reference guide for the reader. For example, eccn 5e001 technology may be exported to a university. This policy and the export control compliance programs are established to facilitate compliance with the u. After publication, we adapted many of the industry specific procedures to fit a more general company profile and serve as a template for the export community. Export compliance program policies and procedures manual. Export controls compliance manual digital version outlining an export management and compliance program emcp at ndsu. Itar compliance, itar regulations, and export licensing are just a few of the topics covered on by excelerate, inc. If your product is on the list, everything else flows from this. Scope and objectives of kus export compliance manual this export compliance manual manual and the policies and procedures contained herein, are designed to ensure that ku complies fully with all applicable u.
A government agent contacts your company and asks to see a copy of your itar compliance manual. The regulations are very precise, and compliance with them is mandatory, not voluntary. If your company is a contractor for another company that has software access, you must file a separate itar compliance letter for your company unless that companys itar. Government regulations that requires all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data. Export controls compliance policy vinyl technology. If your company is a contractor for another company that has software access, you must file a separate itar compliance letter for your company unless that companys itar compliance letter clearly states in writing that your company and all its affiliates are covered under their itar letter. For example, military aircraft are on the usml, as are their engines, electronic controls, and inertial navigation systems, even though such. If you look down the list, you will see that the majority of headings a lot.
Please be aware that technical data documentation, software, drawings, specifications, etc. Export controls compliance division of research the research foundation of state university of new york at binghamton university the purpose of this document is to provide overall guidance on export control regulations and internal procedures. Use this comprehensive checklist to conduct annual compliance audits and detect itar non compliance based on export clearance requirements, itar controlled technical data, use of itar exemptions, and more. If your company falls under these categories, the following information will help answer some of your questions as. Itar compliance software and usml classification ecustoms. Save thousands in consulting fees using the industry leading export compliance program.
Nov 02, 2015 the compliance the supplier wants you to certify is that your company has the basic internal controls to secure itar products and all the technical data associated with those products, such as specification sheet prints, operating instructions, etc. If youre like most organizations, youll reply with something like. If you have any questions regarding the material contained in this export compliance program manual, please contact us office of research integrity and ompliance export ontrols office. Comprehensive operational compliance programs include manuals that articulate. Apr 24, 2017 too often the manual espouses pie in the sky dreams of how the importer or exporter would like to behave when its trade compliance programs are fully developed. The elements of an effective export compliance program bis us. The policy provides a general structure for export control compliance programs throughout the university. Submit your export compliance program ecp manual bis.
For additional information or assistance please contact nancy lewis, assistant. At its most basic, being itar compliant means following all of the requirements of the international traffic in arms regulations itar. International traffic in arms regulations itar is a set of u. Tips for itar export compliance procedures reliant defense. Itar compliance in the cloud focuses on ensuring that information considered technical data is not inadvertently distributed to foreign persons or foreign nations. Emcp and provides information, tools, and templates to help companies develop an emcp. For example, it may be the goal of a company to do a 100% postentry audit of all entries within 30 days of the entered. In addition, since itar regulations apply to the entire supply. This manual is designed to assist you in complying with u. T he objective of itar compliance is to establish executable policies and procedures that will allow your company to successfully manage itar controlled data. Vanderbilt export compliance manual page 5 of 40 last revision march 26, 2018 5 purpose the vanderbilt university export compliance manual manual is intended is to provide guidance on u.
Now you can minimize your export risks by using e2opens export management application to automatically screen partners against the most comprehensive database of restricted parties. Other times, export compliance procedures are so detailed and restrictive that, following them as part of you day to day activity, becomes a full time job in itself. Vanderbilt export compliance manual page 2 of 40 last revision march 26, 2018. The manual is intended to be a resource for faculty, staff and students whose work on campus involves responsibility for export controlled technology.
Each uc location is responsible for managing its own export control compliance program. While the university places a high priority on compliance with export regulations, it is also the mission and policy. Scope and objectives of kus export compliance manual this export compliance manual manual and the policies and procedures contained herein, are designed to ensure that ku complies fully with all. When youre finished well give you recommendations based on your. University of wyoming export compliance manual updated july 2015 export compliance program policies and procedures manual. This university of michigan export control program manual manual describes the university of michigans university or um export control program. Get immediate access to everything you need to start your itarear certification. Export controls compliance manual digital version outlining an export management and compliance program emcp at ndsu research integrity and compliance office of research and creative activity implemented, revised, and updated. The purpose of cornell universitys export control compliance manual is to provide the basis for the operational program and procedures which manage export decisions and transactions in compliance with the three major components of the export control laws and regulations, i. Compliance with these regulations is critical to our successful partnering. The manual is not intended to be a goals and objectives document. Companys export compliance program manual updates, incorporation into.
Compliance requires a documented system, and there are numerous areas that need to be addressed. The usu export compliance program assists university personnel with the identification and management of research projects subject to u. International traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list usml. Scattered throughout the book are examples, templates, charts, figures, and illustrations to assist you in drafting your own export compliance manual. It does not purport to address all relevant trade compliance issues itar regulations 120 that may apply to a companys exporting activities. Itar compliance policy builder this page is a quick start tool to help launch your itar policy program. Feeling overwhelmed by complicated, everchanging export compliance regulations. The compliance the supplier wants you to certify is that your company has the basic internal controls to secure itar products and all the technical data associated with those products. We want to ensure that you are aware of the requirements associated with these regulations. Now you can minimize your export risks by using e2opens export management application to automatically screen. The international traffic in arms regulations itar is a set of u. The official versions of the regulations contained herein are set forth in. Use this comprehensive checklist to conduct annual compliance.
Government, all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data must be. Fishman in an increasingly complicated and transnational business world, there is now greater importance than ever before. No employee or sales representative has the authority to act contrary to this program, nor direct, authorize, or condone. Verify that your products comply with all countryspecific regulations, then. Export control compliance program guidelines january 2019. In conclusion, this is not a guide 100% itar compliance. The first cornerstone concept under itar itar contains a list of products called the u. Mcvey williams mullen june2, 2014 the following is a checklistof key issuesfor companiesto consider in assessingcompliance under the international traffic.
It does not purport to address all relevant trade compliance issues itar regulations 120 that. Directorate of defense trade controls dtc issued license and. Not all munitions are subject to the itar, and certain items that are would not be considered munitions in the popular sense of the term. Department of state, directorate of defense trade controls ddtc. Government regulations that requires all manufacturers, exporters, and brokers of defense articles, defense services, or related technical data to be itar compliant. International traffic in arms regulations itar, enforced by the office of defense trade controls in. Under this export controls compliance policy the policy, violate the no employee may international traffic in arms regulations itar, administered by the u. Under the itar, the exportation of defense articles and defense services is subject to specific licensing requirements. University of wyoming export compliance program updated 114 export compliance program policies and procedures manual. Pat crow wpc to be in full compliance with all applicable laws and regulations. The official versions of the regulations contained herein are set forth in the annual printings of title 22 of the code of federal regulations cfr, as amended in the federal register fr. Items that fall within the department of states jurisdiction see commodity jurisdiction must undergo a.
University of wyoming export compliance manual updated july 2015 export compliance program policies and procedures manual office of research and economic development university of wyoming office of research and economic development dept. Methods for improving ethical trade compliance of an organization jarred a. Checklist of complianceissues underthe internationaltraffic in arms regulations by. Identification, receipt and tracking of itar controlled itemstechnical data methodology used, specifically tailored to corporate structure, organization, and. In order for data to be subject to itar, an it workload or type of data has to be deemed an export according to the us munitions list usml. In general, any physical item made in the united states will be subject to the ear unless the item qualifies for an exemption. Sample export compliance manual itar export compliance. This manual is an example and is intended only as a guide. Itar compliance software for all your trade compliance needs. An itar compliance checklist is a tool used by arms suppliers to determine if their company complies with itar. Mcvey williams mullen june2, 2014 the following is a checklistof key issuesfor companiesto consider in assessingcompliance under the international traffic in arms regulations itar. An effective compliance manual can help you avoid costly fines and penalties. Typically, this access is citizenship based with authorization being defined by the u. The sample export compliance manual published by originally began as a consulting project for one of the largest defense contractors in the united states.
University of wyoming export compliance program updated 114 under the international traffic in arms regulations itar, 22 c. About itar compliance solutions we have the capabilities and experience to deliver the solutions you need to be actively compliant. Munitions list usml if your product is on this list, it is subject to these controls. The ocecc oversees export controls and trade sanctions compliance for the campus and, with implementing departments, it develops and monitors procedures and record keeping systems to ensure compliance. What to include in your companys importexport compliance. Here is a listing of the general topics that need to be covered. Export management and compliance program the purpose of this document is to provide overall guidance on export control regulations and washington university export control internal policy and procedures. Cvg strategy itar export compliance program covers 5 major federal regulatory entities, the manual is 100 pages of policy and procedures with 42 forms. Too often the manual espouses pie in the sky dreams of how the importer or exporter would like to behave when its trade compliance programs are fully developed. Ku export compliance manual the university of kansas.
The program falls under the auspices of the office of research and is managed by the universitys export control officer eco who reports to the vice president for research. Export controls compliance manual research compliance rice. A good compliance program has some widely accepted key components. International traffic in arms regulations itar control the export and import of defenserelated articles and services on the united states munitions list. The hardest part of creating an export compliance program is knowing where to start. Export of defense articles and services international traffic in arms regulations under the international traffic in arms. An export compliance program is a not required by the ear. Under the international traffic in arms regulations itar, 22 c.
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