Archive for the ‘Part 122’ Category


Oct

20

Blame Canada!


Posted by Clif Burns at 8:49 pm on October 20, 2011
Category: DDTCPart 122

Lie DetectorHere I had thought that we had shamed most companies from issuing those grandiloquent press releases claiming that ITAR registration from DDTC constitutes incontrovertible proof that the company can leap tall buildings in a single bound, synthesize gold from base metals and recite the entire text of the International Traffic in Arms Regulations by heart. Backwards.

Then comes along Toronto-based SMTC announcing its registration with this whopper:

Companies receiving this certification must have the knowledge and understanding to fully comply with ITAR regulations and demon-
strate that they have implemented corporate procedures and controls to ensure compliance.

Maybe it’s because they are a Canadian company and just don’t know any better?

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Aug

11

Getting Your Money’s Worth Out of ITAR Registration


Posted by Clif Burns at 6:10 pm on August 11, 2011
Category: Part 122

Big News!As we slide into the slow news cycle that accompanies the dog days of August, our lives have been brightened, just a little bit, by DIVSYS International, which offers up for this blog and the entertainment of its readers an announcement of its ITAR registration. Another in a long series of exaggerated press releases on ITAR registration, DIVSYS wants everyone to know that it “earns” the registration, as if some test were required rather than merely filling out the form and sending the check to DDTC. DIVSYS was informed of the registration in an “approval letter” and now has been “entrusted” by DDTC with registration. Well, at least the company didn’t say it had been “certified” by DDTC as ITAR compliant.

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May

18

We Have A Winner Here. Ding. Ding. Ding.


Posted by Clif Burns at 8:41 pm on May 18, 2011
Category: DDTCITARPart 122

Itar SealEach time a company tries to tout its registration under Part 122 of the International Traffic in Arms Regulations, the claims for the meaning of this registration become more and more outlandish. Scaling peaks not yet scaled by an other registrants is a press release and the website of Aegis Electronic Group, Inc. Somebody in Aegis’s PR department is intent on not letting a red cent of the $2,250 registration fee go to waste.

First, the press release:

Receiving this registration demonstrates that Aegis Electronic Group, Inc. has the knowledge and understanding to fully comply with the Arms Export Control Act (AECE) and International Traffic in Arms Regulations, as well as having corporate procedures and controls in place to ensure compliance.

Er, no. Registration demonstrates that Aegis figured out how to fill out a form DS-2032 and pay the registration fee. There’s no test of Aegis’s knowledge or audit of its corporate procedures and controls. All that registration certifies is that Aegis had $2,250 in its bank account when its check for the registration fee cleared.

And then we have the website. At the top of the site, we have this language:

Aegis Electronic Group, Inc. is proud to be recognized by the United States Government as an International Traffic in Arms (ITAR) registered manufacturer/exporter.

“Recognized.” Did I miss the awards ceremony?

But best of all, the website is adorned with a seal to certify registration. Yes, an official looking seal that someone in their PR department cooked up on Adobe Illustrator and emblazoned with the legend “International Traffic in Arms Regulations Compliant.” It’s gold too. The seal is shown in the illustration on the left side of this post.

I now predict an out-of-control seal proliferation race as new registrants come up with more and more elaborate and official looking seals to outdo the last one cooked up by a registrant. Buy stock in Adobe now and encourage your kids to become graphic artists to get in on the ground floor of all this.

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Mar

16

First Let’s Make Sure We’ve Got the Name Right


Posted by Clif Burns at 10:05 pm on March 16, 2011
Category: Part 122

Yippee!It’s been a while since this blog has seen one of the infamous press releases from a company announcing that the company has registered with the Directorate of Defense Trade Controls (“DDTC”). A reader today brought to my attention a press release from Rave Computer announcing that it is now “ITAR registered.”

As is normal in these cases, the company does its best to try to leave the impression that registration is a certification or endorsement by DDTC of the company’s compliance policies:

Rave Computer developed and implemented ITAR policies, procedures and employee training.

But in the previous sentence, Rave says:

The Office of Defense Trade Controls in the State Department interprets and enforces ITAR. Its goal is to safeguard U.S. national security and further U.S. foreign policy objectives.

Oops. DDTC hasn’t called itself the Office of Defense Trade Controls for almost a decade. Do you think Rave may be using ten-year old copy of the ITAR as the basis for certifying its compliance with the regulations and obtaining registration?

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Jun

24

Registration Follies


Posted by Clif Burns at 9:59 pm on June 24, 2010
Category: DDTCITARPart 122

Under ScrutinyRegular readers are no doubt familiar with this blog’s occasional posts poking fun of press releases from defense manufacturers noting that the company had “achieved” registration with the State Department’s Directorate of Defense Trade Controls (“DDTC”). A common feature of many of these press releases is to try to portray registration under Part 122 of the International Traffic in Arms Regulations as an endorsement by DDTC of the company’s export compliance expertise and procedures.

Well, I think a new bar was set by this press release from Virginia-based Zestron Corporation

ZESTRON process and service solutions, recently renewed its official International Traffic in Arms Regulations (ITAR) registration with the US Department of State, Directorate of Defense Trade Controls.

After several weeks of careful review of ZESTRON’s corporate structure, security, record keeping and procedures for handling sensitive military and intelligence applications, the company successfully passed the system’s strict requirements. The renewal of this registration demonstrates that ZESTRON is dedicated to adhering to the regulations that control the export and import of defense-related articles and services on the United States Munitions List.

Honestly, that doesn’t just take the cake. It takes the table the cake is on, the house where the table is, and the city in which the house is located. There is no scrutiny by DDTC of corporate structure, much less “several weeks” of such scrutiny. Nor is there any review of a company’s procedures for handling military and intelligence applications. And don’t get me started on the import business in the press release. The only strict requirement that a registered company has passed is that it was able to fill out the registration form correctly and submit it with the required fee.

Here’s a new export reform proposal: the DDTC should revoke the registration of any company that issues a press release incorrectly describing the significance of registration.

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