ITAR Compliance Program and Supply Chain BestPractices: How to Develop and Implement EffectiveCompliance Manuals, Policies and Procedures

October 21, 2014 5:30pm

Ben Gaffield
Corporate Technology Control Officer and Director, Trade Compliance
Elbit Systems of America

Nancy Ceglarski
Manager, International Trade Compliance
Northrop Grumman Corporation (Rolling Meadows, IL)

ITAR Compliance Program

  • Key elements and best practices for effective ITAR compliance
  • Identifying and empowering the right internal resources and personnel
  • Developing and updating your compliance manual, procedures and processes, including policy
  • Statements and message from senior management
  • Creating an anonymous reporting tool and compliance hotline

Supply Chain, End-Use and End-User Screening

  • Where the exporter’s responsibility for third party compliance begins and ends
  • Vetting third parties, including subcontractors, freight forwarders, distributors, customs brokers, customers, re-sellers and others: What to look for and ask at the due diligence stage
  • Monitoring ITAR compliance of third parties
  • Recordkeeping: What documents/information to collect from foreign third parties, and how to review them
  • Building an effective end use/end user screening program
  • Safeguards to implement for orders and shipments, and when to terminate the relationship because of export enforcement risks