This course is designed as a participative workshop. A hypothetical case study, involving a potential ITAR violation, will lay out the factual background to facilitate the discussion. Highlights of what the course will cover include:
This participative discussion and the intensive analysis of the case study will result in the identification of best practices that will assist participants in developing and improving their own internal compliance audit strategies and procedures.
ITAR Compliance and Audits Course Curriculum
ITAR compliance is a business imperative for companies in the defense industry. Companies increasingly are subject to significant penalties, including consent decrees mandating outside compliance monitors.
This course offers a practical approach to identifying and dealing with instances of possible noncompliance with the ITAR, and to improving audit and compliance processes to correct deficiencies and minimize the risk of future violations. The course will use a hypothetical scenario as the basis for a discussion of ITAR compliance and audits. Each participant will work with a case study hypothetical. The hypothetical will provide the background facts about a fictional company and several potential export violations, as well as copies of the company's export compliance procedures.
The course will start with a discussion of how to react to the hypothetical:
After these issues are discussed, participants will outline the basics of a preliminary voluntary disclosure letter that would be sent to the DDTC. The instructors will then distribute and explain a best practices disclosure letter based on the facts in the hypothetical.
Once the initial disclosure letter has been filed with the DDTC, the discussion will continue with a focus on the conduct of an investigation and preparation of a report. The report is a follow-up to the initial disclosure report:
Participants will then outline the basics of a followup disclosure letter that would be sent to DDTC. The instructors will distribute and explain a best practices follow-up disclosure letter, and then discuss the settlement process.
Much of the course will include participation and discussion about policy enhancements and internal auditing techniques to enhance the ITAR compliance posture. The instructors will facilitate wide-ranging discussions to provide time for all participants to learn from each other.
