Itar training london

These items are subject to the same sets of controls under ITAR as physical products. So how does someone export software and technical data? The State Department has a very broad definition of how one exports these items. This is the first criminal indictment and conviction under the Deemed Export Rule. A company in California was developing technology in its lab.

The items were subject to export restrictions. They were indicted and convicted. What exactly is a foreign national? Under the export laws — if a foreign person is in the US and has permanent resident alien status — a green card, they are treated as if they are a US citizen under the export laws. So someone who is here on an H1B visa, a business visa, a student visa, or no visa treated as a foreign person. Another cornerstone concept is services.

If an item is on the munitions list, performing services for a foreign party related to that item is also on the list and subject to these controls. Installation services, troubleshooting services, warranty repair services.

Engineering services, retrofitting services, consulting services, et cetera. Here are some examples of items on the US Munitions List this of course is not a complete list of all items : Military electronics and computers, military communication systems, certain flight control systems, UAVs, military navigational systems, certain personal protective equipment and gear, etc.

Usually we recommend that everyone involved in SBIR contracts or dealing with the defense industry review the U. Munitions List, to see if their products or services are on the list.

Parts and components is a very important concept. In many cases if an item is on the Munitions List, parts and components that are specially designed for that item are also on the list and subject to ITAR. Also, in some cases if the end item is on the list, the parts and components may be listed on the Commerce Control List and regulated under the Export Administration Regulations instead.

So for example, Category 6 is naval vessels so a naval destroyer is on the list. But the USML also includes many of the parts, components, accessories, and subsystems that are specially designed for that naval destroyer. I mentioned that services are regulated previously.

In addition, other services are also regulated, such as military training. Also, providing military advice to foreign parties is on the list and subject to ITAR.

Was it developed with US DoD funding, or with other government agency funding or contracts? Expect to leave these seminars with an understanding of the rules that will allow you to minimize any delays in your exports, minimize your costs of compliance, and reduce the risk of inadvertently violating the law, giving your organization a competitive advantage and a compliance program on solid footing.

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