Defense Supplier: ITAR Compliance & Export Control Implementation
A growing defense supplier achieved full ITAR compliance with zero violations — securing $25M in new DPAS-rated contracts.
The Challenge
A growing defense supplier needed full ITAR compliance and DPAS-rated contract capability to pursue $25M in new DoD and prime contractor opportunities.
Company had grown from commercial into defense work without establishing formal export controls
Handling ITAR-controlled technical data without proper classification or access controls
No Technology Control Plan (TCP) despite employing foreign national workers
DPAS priority-rated orders being accepted without understanding compliance obligations
Previous informal compliance approach would not survive a DDTC or BIS audit
Our Approach
Implemented comprehensive ITAR/EAR compliance program covering registration, classification, physical security, personnel controls, and DPAS management.
Phase 1: Export Classification & Registration (Month 1)
Reviewed all products and technical data against USML and CCL. Obtained DDTC registration. Classified controlled articles and established commodity jurisdiction determinations for dual-use items.
Phase 2: Technology Control Plan & Physical Security (Months 2-3)
Developed comprehensive TCP addressing foreign national access restrictions. Implemented physical security controls including restricted areas, visitor protocols, and IT access controls for ITAR data.
Phase 3: Compliance Programs & Training (Months 3-5)
Built export compliance manual covering all ITAR/EAR requirements. Trained all personnel on export control obligations. Established self-disclosure procedures, record retention requirements, and compliance monitoring.
Phase 4: DPAS Implementation & Contract Readiness (Months 5-6)
Implemented DPAS priority rating management system for DO and DX rated orders. Established procedures for accepting, rejecting, and flowing down priority ratings. Prepared compliance documentation for prime contractor audits.
Results & Impact
Achieved full ITAR compliance with zero violations. Qualified for DX-rated DPAS contracts and secured $25M in new defense business.
Passed first DDTC compliance review with no findings — export control program rated exemplary
Qualified for and won 4 new defense contracts requiring ITAR compliance and DPAS capability
Fully qualified to accept and manage both DO and DX priority-rated orders
Passed 3 prime contractor ITAR compliance audits with zero findings
Additional Outcomes
“We went from informal export controls to a program that passed DDTC review with flying colors. The DPAS implementation alone opened $25M in new defense contracts we could not have pursued before.”
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