May
18
We Have A Winner Here. Ding. Ding. Ding.
Posted by Clif Burns at 8:41 pm on May 18, 2011
Category: DDTC • ITAR • Part 122
Each 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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Copyright © 2011 Clif Burns. All Rights Reserved.
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10 Comments:
What does the government do to earn the $2,250 fee? If we were paying fees for government services instead of taxes, maybe that would be about right.
I never get tired of laughing at these. Thanks, Clif.
As entertaining as this is, announcements of ITAR registration, particularly when touted on a company’s website, does serve a useful purpose. It informs customers (and employees) that company has ITAR controlled products, it forces company management to have a clue about the ITAR because someone will ask what it means, and it reminds customers to inquire further about the currency of such registration. On the otherhand, DDTC isn’t known for its sense of humor, so the entertainment value could be counterproductive.
@KNDL. I certainly believe that manufacturers of defense articles should inform customers of their registration status, and the website is a great place to do it for the reasons you state. But they can do that without all the exaggerated claims and implications that they have been government-certified as ITAR compliant, which is misleading. All they should say is this: “XYZ Company is registered under part 122 of the ITAR as is required by law for all manufacturers of defense articles.”
Do you think Aegis would mind if I used their ITAR seal as my facebook profile picture, or do you think they have it TM? I would like all my facebook friends to know that I too was recognized as an ITAR registered exporter, I just didn’t go to the ceremony since I was filming a movie outside of the country at the time and had Charles Nelson Reilly accept on my behalf.
This definitely tops my list of false advertising! Thanks for sharing.
I’m DDTC registered AND I saved a ton of money on my auto insurance!
I don’t remember people doing this before, is this a new phenomenon or did we just not notice it before the internet?
I doubt if DDTC would ever agree to do something that was useful, but perhaps we could impose upon them to publish an announcement on their website to the effect that registration does not equate to approval.
(a) This may be deceptive advertising for purposes of the FTC Act.
(b) Whenever I hear a part or service provider claim “We’re 100% ITAR compliant!” instead of “We’re registered with DDTC, and this ITAR stuff can be challenging,” my spider-sense starts tingling. Credibility matters.
Possibly the PR department decided that a positive news item regarding compliance awareness was required to offset the recent negative – OFAC Enforcement Information for April 7, 2011
