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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:

  • Analysis and discussion of a Hypothetical Corporate ITAR violation
  • What you do immediately and how to prevent an ongoing violation
  • Should (or how will) the DDTC be notified?
  • Preparation of the Draft Preliminary
  • Disclosure
  • Development of the Investigative Workplan
  • Development of the Correction Action Plan
  • Preparation of the Follow Up Disclosure Report
  • Settlement Strategies and Consent Agreements
  • Long Term Compliance Strategies
  • How to develop an Internal Audit Plan through Industry Best Practices

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.

Dates and Locations
October 25-26, 2017
American Management Association
Arlington, VA
8:00 AM - 3:00 PM
Schedule for Hilton Head
8:00 AM - 3:00 PM
Schedule for La Jolla, CA
9:00 AM - 4:00 PM
Schedule for all other locations

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:

  • Is there an ongoing violation that must be stopped?
  • If so, how will it be stopped?
  • Should (or how will) the Directorate of Defense Trade Controls (DDTC) be notified?
  • How will the issue be coordinated with senior management?
  • How will the issue be explained to middlemanagers and line employees?
  • Will customers or subcontractors be affected?

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:

  • Who should be involved?
  • How should the investigation be structured?
  • How should any interim requests for information from DDTC be treated?
  • What sorts of process improvements and corrective action should be implemented?
  • How should potential penalties be explained to senior management?

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.


Andrew D. Irwin is a Partner in the Washington office of Steptoe & Johnson LLP, where he is a member of the International and Litigation Departments. He practices at the intersection of international regulatory law and government procurement, focusing primarily on corporate investigations and related compliance counseling. He has a particular background in laws and regulations that relate to export controls/sanctions, foreign corruption, and government contracting fraud.  He also has considerable experience in general corporate ethics/compliance counseling,  as well as ethics/compliance program administration and development. He has conducted investigations in Europe, Asia, and the Middle East (including on the ground in Iraq). Prior to coming to Steptoe, Mr. Irwin spent several years as inside counsel for one of the world’s largest engineering and construction companies.

Mr. Irwin has considerable experience counseling clients in a number of industries regarding their compliance with the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).  Much of his practice relates to enforcement matters, including voluntary disclosures and related internal investigations.  He also advises clients regarding developing policies and procedures to prevent and detect violations and preparing license, classification and commodity jurisdiction requests. Mr. Irwin has also counseled clients regarding all major US sanctions regimes administered by the Office of Foreign Assets Control (OFAC) and conducted investigations regarding potential sanctions violations.  In addition, he has helped clients address a wide-range of issues related to working in Iraq.


Mr. Irwin also has extensive Foreign Corrupt Practices Act (FCPA) experience. He has investigated potential FCPA violations in numerous locales, including having conducted dozens of witness interviews. In addition, he has conducted FCPA due diligence and audits of sales agents, as well as prepared corporate policies and training materials regarding FCPA compliance. He frequently draws upon his background in public procurement in such matters. 


In addition, as inside counsel to a major government and international contractor, Mr. Irwin advised senior management, business development, and procurement personnel regarding a full range of contract formation and administration issues involving numerous significant programs for the US Departments of Defense and Energy, as well as the US Agency for International Development. In addition, Mr. Irwin supervised bid protest litigation and was responsible for a number of Freedom of Information Act-related matters.


Mr. Irwin is on the Advisory Board for West’s Government Contractor and was a frequent contributor to International Government Contractor.  He has spoken at the Government Contracts Year in Review Conference, usually on the FCPA, since the 2007 conference.  He is a co-editor, with Ed Krauland, Jack Hayes and Meredith Rathbone, of Thomson Reuters's West International Traffic in Arms Regulations Handbook.


Mr. Irwin received his undergraduate degree from Princeton and his law degree from The GeorgeWashington University.  He has also studied at The University of Edinburgh.


Robert D. (Bob) Vander Lugt is the Director of Export Compliance, Northrop Grumman Corporation.  As a part of the Northrop Grumman Export Import Shared Service (“EISS”) management team, Mr. Vander Lugt is responsible for export compliance and training matters.  He and his staff work with the operating sectors of the company to:  craft, implement and maintain export compliance policies and procedures which are maximally effective across the range of the company’s regulated activities, including platform integration, system and subsystem manufacturing, and the provision of defense services; promote standardization and best practice sharing across the enterprise; ensure adequate training of employees; and otherwise manage export compliance risks.  Prior to taking his current position at Northrop Grumman, Mr. Vander Lugt served as the empowered official for shipbuilding and night vision businesses within the corporation.


Prior to joining Northrop Grumman in 2003, Mr. Vander Lugt practiced national security law in Washington, D.C., where he represented many of the major U.S. and European  defense contractors in export control/technology transfer and sanctions compliance investigations, False Claims Act cases, bid protests, claims, suspension and debarment proceedings, merger and acquisition reviews, and security clearance cases.


Mr. Vander Lugt is Commander in United States Navy Reserve, and presently serves as the Executive Officer of NR JIOCSOUTH 0270, providing intelligence support to SOUTHCOM.  He has served on the intelligence staff of the IFOR Commander during U.S. operations in the Balkans, the Staff of the Commander, Navy Reserve Intelligence Command, and on the Intelligence Task Force of the ABA’s Standing Committee on Law and National Security.


As an adjunct professor at the Georgetown University Law Center, Mr. Vander Lugt designed and taught a course in the law of international institutions.  He is coauthor of International Rules:  Approaches from International Law and International Relations, published by Oxford University Press in 1996 and widely used as a graduate-level textbook in the field.  He has lectured on international and national security law topics in the U.S. and abroad for the Republic of China Ministry of Finance, the Forum for U.S.-Soviet Dialog, Georgetown University, the University of Virginia, the National Defense University, the National University of the Republic of China, the International Studies Association, the American Society for International Law, Federal Publications, the National Defense Industries Association of the United States, the Defense Manufacturers Association of the United Kingdom, and the Society for International Affairs, and the Space Coast Trade Council. 


Mr. Vander Lugt received his undergraduate degree in History and Government from Oral Roberts University, and his law degree from the University of Virginia.  He lives with his wife Ruthie and son Joel in Plano, TX, and enjoys reading history & biography, kayaking, cycling, and chasing Joel’s baby jogger around the park.

Jack R. Hayes is Of Counsel in the Washington, D.C. office of Steptoe & Johnson LLP, where he is a member of the International Regulation and Compliance group.  Mr. Hayes has considerable expertise in counseling clients about how to implement successful strategies in the context of overlapping international trade regulatory areas, including with respect to export controls, economic sanctions, anti-money laundering, anti-boycott, and foreign corruption compliance. 

Mr. Hayes has experience counseling clients in the defense and commercial sectors regarding their compliance with the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR).  Much of his practice relates to enforcement matters, including voluntary disclosures, internal investigations of apparent export control violations, and assessments of compliance obligations in accordance with relevant international trade requirements.  He also has assisted clients in the preparation of legal memoranda interpreting provisions of the ITAR and EAR, license applications, advisory opinion requests, commodity jurisdiction and classification analyses, including with respect to encryption technology, and compliance programs, policies, or manuals.  He is a co-editor, with Andy Irwin and Ed Krauland, of Thomson West’s International Traffic in Arms Regulations Handbook.

Mr. Hayes has advised clients in various industries regarding compliance with U.S. and multilateral economic sanctions targeting specific countries, such as Cuba, Iran, Sudan, and Myanmar (Burma), and persons or entities acting contrary to the interests of the United States, including terrorists, proliferators of weapons of mass destruction, and narcotics traffickers.  He has assisted clients in the preparation of license and advisory opinion requests for, submission of blocking reports to, resolution of administrative subpoena requests in connection with, and related oral advocacy concerning officials in the U.S. Department of the Treasury and U.S. Department of State.  This practice also has involved counseling clients on the intersection of economic sanctions and anti-money laundering/anti-terrorism financing laws and regulations, including the creation of compliance programs, know-your-customer and due diligence best practices, and reporting requirements.

Mr. Hayes has counseled clients on anti-corruption compliance issues, with particular emphasis on the intersection of the Foreign Corrupt Practices Act and Part 130 of the ITAR.  He also has prepared multi-jurisdictional corporate policies, compliance manuals, due diligence tools, draft compliance language for international agreements or terms and conditions, and ethical codes of conduct to assist clients with anti-corruption initiatives.

Mr. Hayes earned his B.A. from Furman University and his J.D. from Northwestern University.  Prior to law school, Mr. Hayes worked on a number of legal international trade and tax matters involving the jurisdiction of the House Committee on Ways and Means and the Senate Committee on Finance.

Meredith Rathbone is a Partner with the law firm of Steptoe & Johnson LLP in Washington, D.C., where she practices in the International Law Department. Ms. Rathbone focuses her practice on counseling clients regarding international regulations and compliance, including compliance with U.S. export controls and economic sanctions laws.

Ms. Rathbone has advised and assisted clients in undertaking numerous internal investigations in the United States and abroad relating to compliance with the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR) and U.S. sanctions laws. She regularly advises clients on making voluntary disclosures and has interfaced on behalf of clients with Government officials following such disclosures. In addition, Ms. Rathbone is experienced in assisting clients in navigating all other aspects of export controls and sanctions compliance, including the establishment of compliance programs designed to prevent inadvertent violations of the law, undertaking commodity classification and jurisdiction assessments, seeking licenses, obtaining approval for and managing Technical Assistance Agreements (TAAs) and Manufacturing License Agreements (MLAs), and undertaking internal audits. Ms. Rathbone also advises clients on customs, anti-corruption, and international government procurement matters.

Ms. Rathbone writes and speaks regularly on international regulatory compliance matters. She is a Vice Chair of the American Bar Association, Section of International Law’s Export Controls and Economic Sanctions Committee. In addition, she has taught courses relating to international law as an adjunct professor at Georgetown University and Georgetown University Law Center.

Ms. Rathbone earned her undergraduate degree from the Georgetown University School of Foreign Service, and her law degree from Georgetown University Law Center. She has also studied in Finland, Russia, and Italy.


Certificates of Completion are provided to all seminar participants who attend Federal Publications Seminars courses following the event, upon request.
All Federal Publications Seminars courses meet the course requirements of the National Contract Management Association’s certification programs. We are a proud Education Partner of the NCMA.
Federal Publications Seminars is part of West Professional Development, which is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website:
This Program is eligible for: 13.0 (CPE) hours of credit
Program Level: Basic
Program Prerequisite: None
Advance Preparation: None
Method: Group-Live
Defense Acquisition Workforce members must acquire 80 Continuous Learning Points (CLP) every two years from the date of entry into the acquisition workforce for as long as the member remains in an acquisition position per DoD Instruction 5000.66. We will provide you with documentation of points awarded for completing the event.
This Program is eligible for: 11.0 (CLP) hours of credit
States have widely varying regulations regarding MCLE credit. LegalEdcenter is an approved provider in AL, AK, AR, CA, GA, IL, ME, MO, MS, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VI, VT, WA, WI, and WV. Credit may be applied for in other jurisdictions on request and in accordance with state MCLE rules.
** Please note that because some states are changing their policy on CLE reporting, you will need to fill out the request for credit from Federal Publications Seminars within 10 business days, or we may not be able to issue credits for the program.
This Program is eligible for: 11.0 (60 minutes), 13.0 (50 minutes)
American Management Association
2345 Crystal Drive, Second Floor
Arlington, VA 22202

Coffee, tea and water will be served throughout the day with an afternoon cookie break.  Breakfast and lunch are on your own.

Yellow & Blue Line – METRO Stop – Crystal City
From the METRO - AMA is 2 blocks east and 4 blocks south on Crystal Drive

There is not a room block for this location, however the AMA offers special hotel rates.  Please visit

Basic or fundamental subject matter is covered. Courses are geared to general knowledge or can be taken as a refresher.
Specific topics or issues within a topic area are covered. Students should be familiar with terms of art and general concepts concerning the course topic.
Workshops and class discussions cover specific subject matter in-depth, and participation is strongly encouraged. Attendees should have at least 2-3 years' experience in the area of study.
Courses build upon students' knowledge and experience, and cover complex issues within the subject matter. Should have 4-5 years' mastery of subject for in-depth analysis.
Masters-level programs designed for professionals with 5+ years' experience. Courses cover in-depth and technical analysis on specific subjects and updates on current issues.
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ITAR Compliance: A Voluntary Disclosure and Best Practices Workshop
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Date Location
October 25-26, 2017 Arlington, VA
By Phone
Call (888) 494-3696