ITAR Compliance Implementation
We don't just advise on ITAR — we've implemented export control programs in numerous defense facilities. Our team has managed DPAS-rated military purchasing operations, navigated EAR/ITAR jurisdiction determinations, and built Technology Control Plans from the ground up.
Penalties reach $1.3M per violation. Criminal prosecution is real. Don't trust your export control program to consultants who've only read the regulations — work with practitioners who've lived them.
Export Control Regulatory Frameworks We Navigate
Four interlocking regulatory frameworks govern defense trade. We have hands-on implementation experience across all four.
International Traffic in Arms Regulations
Controls the export and import of defense articles, services, and technical data on the U.S. Munitions List (USML). Administered by the State Department's Directorate of Defense Trade Controls (DDTC).
Export Administration Regulations
Controls dual-use items, commercial items with military applications, and items on the Commerce Control List (CCL). Administered by the Bureau of Industry and Security (BIS).
Defense Priorities & Allocations System
Ensures timely availability of industrial resources to meet national defense requirements. We have direct experience managing DPAS-rated orders for military purchasing operations.
Defense & Federal Acquisition Regulations
Governs acquisition processes for DoD and federal agencies. DFAR supplements add defense-specific requirements including cybersecurity (DFARS 252.204-7012), counterfeit parts, and supply chain security.
ITAR + AS9100 Audit Integration
We assess ITAR compliance indirectly during every AS9100 and defense audit we conduct. Most consultants treat quality management and export control as separate silos. We don't. When we audit your AS9100 system, we're simultaneously evaluating whether your ITAR controls are embedded, functional, and audit-ready. This integrated approach catches gaps that other auditors miss entirely — and every time we walk into a facility that another firm certified, we find non-conformance.
What We Deliver
Comprehensive ITAR/EAR compliance implementation — from initial assessment through ongoing monitoring. Built by practitioners, not theorists.
ITAR Gap Assessment
Comprehensive evaluation of your current export control program against ITAR/EAR requirements. We identify every vulnerability, non-compliance risk, and exposure point — with prioritized remediation roadmap.
Technology Control Plan (TCP)
Development and implementation of your TCP covering physical security, IT security, visitor access controls, personnel screening, and technical data handling procedures.
USML/CCL Classification
Proper classification of your products, technical data, and defense services against the U.S. Munitions List and Commerce Control List categories.
Empowered Official Program
Establishment of your Empowered Official structure, delegation of authority, and decision-making framework for export control determinations.
Export License Management
DSP-5, DSP-73, DSP-85 license application preparation, TAA/MLA drafting, and license compliance tracking systems.
Deemed Export Controls
Foreign national access programs, deemed export procedures, and technology transfer controls for facilities with international employees or visitors.
DDTC Registration & Compliance
State Department registration, annual registration renewal, and DDTC compliance reporting requirements.
DPAS Order Management
Defense Priorities and Allocations System compliance — rated order acceptance, scheduling, rejection procedures, and Special Priorities Assistance (SPA) requests.
Training & Awareness Program
Customized ITAR/EAR awareness training for all personnel levels — from shop floor workers to executives — with annual refresher programs and competency verification.
Voluntary Disclosure Support
If violations are discovered, we guide you through the DDTC or BIS voluntary self-disclosure process to mitigate penalties and demonstrate good faith compliance.
AS9100 + ITAR Integration
We assess ITAR compliance indirectly during AS9100 and defense audits — ensuring your quality management system and export control program work as one unified system.
Ongoing Compliance Monitoring
Periodic compliance reviews, regulatory update monitoring, and program health assessments to keep your export control program current as regulations evolve.
Our Implementation Process
Six proven phases. We've done this across numerous defense facilities. No guesswork.
Initial Assessment
Comprehensive review of your operations, products, technical data, and current export control practices against ITAR/EAR requirements.
Classification & TCP Development
Product/data classification, Technology Control Plan drafting, and compliance program architecture.
Implementation
Physical security upgrades, IT controls, personnel screening, training deployment, and procedure rollout.
Internal Audit
Full compliance audit to verify every ITAR/EAR requirement is met before any external scrutiny.
Program Validation
Mock DDTC/BIS audit, corrective action closure, and management review of compliance status.
Ongoing Monitoring
Continuous compliance monitoring, regulatory updates, annual training refreshers, and program optimization.
ITAR Violation Penalties Are Severe
$1.3M+
Per civil violation (adjusted annually)
20 Years
Maximum criminal imprisonment per violation
Debarment
Banned from all future export activities
Don't wait for a compliance incident. A proactive ITAR assessment costs a fraction of a single violation.
Not Sure Where You Stand? Take the Free Screener
Our ITAR Readiness Screener gives you a high-level compliance risk score across 8 categories in under 5 minutes. It shows you WHERE your gaps are — then our formal Gap Assessment shows you exactly HOW to fix them.
Take the Free ITAR Readiness ScreenerFrequently Asked Questions — ITAR Compliance
What is ITAR and who does it apply to?
ITAR (International Traffic in Arms Regulations) applies to any U.S. person or company that manufactures, exports, or brokers defense articles, defense services, or related technical data listed on the U.S. Munitions List. If you make parts for military aircraft, weapons systems, satellites, or defense electronics — ITAR applies to you. Violations carry penalties up to $1.3M per violation and criminal prosecution.
What's the difference between ITAR and EAR?
ITAR controls defense articles on the U.S. Munitions List (State Department/DDTC). EAR controls dual-use and commercial items on the Commerce Control List (Commerce Department/BIS). Some items fall under both. Proper jurisdiction determination is critical — misclassification is itself a violation.
Do we need ITAR compliance for AS9100 certification?
AS9100 certification does not explicitly require ITAR compliance — but if your facility handles ITAR-controlled articles or data, you absolutely need both. We assess ITAR compliance indirectly during AS9100 and defense audits. Many of the facilities we audit have ITAR obligations that their previous consultants overlooked.
What are the penalties for ITAR violations?
Civil penalties up to $1,313,996 per violation (adjusted annually). Criminal penalties up to $1M and 20 years imprisonment per violation. Additionally, DDTC can debar your company from future export activities — effectively shutting down your defense business. Voluntary self-disclosure can significantly mitigate penalties.
How long does ITAR implementation take?
Typically 3-6 months depending on facility complexity, number of ITAR-controlled programs, and current compliance maturity. Companies with existing security infrastructure (clearances, access controls) can move faster. The Technology Control Plan development is usually the most intensive phase.
Can you help if we've already had a violation?
Yes. We have experience guiding organizations through the voluntary self-disclosure process with both DDTC and BIS. Early disclosure with a credible corrective action plan significantly reduces penalties. Time is critical — contact us immediately.
What is a Technology Control Plan?
A TCP is the documented program describing how your facility controls access to ITAR-controlled technical data and defense articles. It covers physical security (locked areas, access badges), IT security (network segmentation, encryption), personnel controls (citizenship verification, NDA requirements), visitor procedures, and training requirements.
How does DPAS work?
The Defense Priorities and Allocations System requires contractors to accept and prioritize rated orders (DO and DX ratings) over commercial work. Non-compliance can result in criminal penalties. We have direct experience managing DPAS-rated orders for military purchasing operations and can implement your compliance program end-to-end.
Industries Requiring ITAR Compliance
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