Archive for the ‘Part 122’ Category


Mar

16

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


Posted by 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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Copyright © 2011 Clif Burns. All Rights Reserved.
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Jun

24

Registration Follies


Posted by 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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Copyright © 2010 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)