It has been a while since we’ve highlighted the ever popular press releases of companies touting their ITAR registrations as the best thing since ShamWows and Chia Pets. Today’s companies that will do the Part 122 walk of shame are Professional Aviation Associates and American Industrial Systems.

Take it away, Professional Aviation Associates:

Professional Aviation Associates, a Greenwich AeroGroup company announced it recently became International Traffic in Arms Regulations (ITAR) certified.

According to the Directorate of Defense Trade Controls (DDTC), the U.S. Government requires all manufacturers, exporters, and brokers of defense articles, defense services or related technical data to be ITAR compliant.

The ITAR certification allows Professional Aviation Associates to supply rotables to military aviation operators of both fixed wing and rotorcraft models, as well as parts and tooling to foreign militaries

Of course, the only thing that DDTC has “certified” for PAA is that PAA could figure out the names of its officers and directors, put them on a piece of paper and send them to DDTC with a check that didn’t bounce. All certifications should be this easy. I do hope that during this intensive certification process, PAA learned that it needs more than just its certification to supply “parts and tooling to foreign militaries.”

But today’s winner is American Industrial Systems:

American Industrial Systems Inc. (AIS), an ISO 9001:2008 certified supplier and manufacturer of rugged computer and display has announced completion of the International Traffic in Arms Regulations (ITAR) registration with the Directorate of Defense Trade Controls (DDTC). ITAR is a set of United States government regulations that control [sic] the export and import of defense-related articles and services on the United States Munitions List (USML). This registration, and with [sic] our commitment to ISO 9001 standards, documents AIS’s dedication to adhering to the strict regulations that control the export and import of defense-related services. AIS has proven their knowledge, understanding, and compliance to [sic] the US Department of States [sic] regulations in addition to the inclusion of defined corporate procedures and controls.

Well, I can tell you at least one subject that isn’t on the ITAR certification exam.

We all know about exporters who, having spent the money to register with the Directorate of Defense Trade Controls (“DDTC”), can’t resist crowing about it, with some even implying in press releases that registration is a certification from DDTC that the registered exporter has passed some test and is now certified as ITAR-compliant, which, of course, is untrue.

But here’s another response to the giddy euphoria that follows on the heels of a successful registration: post the registration code and the DDTC registration letter on your website! That is exactly what E.R. Precision Optical did. Of course, the folks at E.R. were probably not aware that DDTC says

The code is proprietary to the registrant and should be handled as such. Company registration codes should not be posted online or given out freely to the public.

Of course, that raises the more interesting question: why should this registration number be confidential? It’s not like I can take E.R.’s number from the web and use it to start applying for export licenses in my own name. Further, DDTC spokespeople have said that exporters should make sure that they only deal with registered subcontractors even though DDTC refuses to answer inquiries as to whether particular parties are even registered or not. And arguably using an unregistered manufacturer is a violation of section 127.1(d) of the ITAR.

So how do you find out if someone who manufactures defense articles is registered? The best way is to ask that company for a copy of the registration letter which, of course, the DDTC says is “double secret.*” Otherwise, you just have to take their word for it. At least when companies like E.R. post the registration letter and code online, you can be fairly certain, Photoshop forgeries aside, that they are registered.

[h/t to Chris Adams for pointing out the E.R. website to me.]

*Naughty language alert if you click this link and view the video. May not be safe for certain workplaces.

Here 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?