Bring any seminar or course directly to your staff through the Federal Publications’ In-House Presentations Program.
Get 10% Off Your Next Purchase
Email Address * Name
Title Organization
Privacy Policy


You'll soon be receiving updates about special offers, events, books & more.
Continue to browse our site to:

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

This course will be scheduled soon. Please enter your information below to receive a notification when the class is scheduled.

Email Address *
First Name
Last Name
Address 1
Address 2
Zip Code
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 Irwin, Partner, Jenner & Block
Mr. Irwin is a member of both the Government Contracts and the Government

Controversies and Public Policy Litigation Practices. With more than 20 years of

experience, Mr. Irwin focuses his practice at the intersection of government

procurement and international regulatory law, concentrating primarily on

corporate investigations and compliance counseling. His unique background

includes experience on export controls, economic sanctions and the Foreign

Corrupt Practices Act (FCPA).

Mr. Irwin has a wide-ranging export control practice. He has handled

investigations and voluntary disclosures for companies in a range of industries,

including aerospace and defense and high-tech. Much of his work has involved

the International Traffic in Arms Regulations (ITAR), but he has also managed

substantial Export Administration Regulations (EAR) enforcement matters. He

also has counseled clients regarding all major economic sanctions regimes

administered by the Office of Foreign Assets Control (OFAC), conducted a

number of FCPA investigations and reviews around the world, and has advised

clients on Committee on Foreign Investment in the United States (CFIUS)


Mr. Irwin has handled significant False Claims Act and ethics/compliance

matters, including those with related international regulatory concerns. While inhouse

early in his career, he supervised major protests and handled issues

relating to work with the Department of Defense, Department of Energy and the

United States Agency for International Development.

A prolific contributor to government contracts publications, Mr. Irwin’s writing

often focuses on overlapping issues such as export controls and anti-corruption.

He is a member of the advisory board for Thomson Reuters’ Government

Contractor and the conceiver and co-editor of Thomson Reuters’ ITAR

Handbook. He speaks at conferences and events worldwide. His engagements

have included, among others, speaking on international compliance issues at

Thomson Reuters’ “Government Contracts Year in Review,” the largest national

government contracts legal conference. He conceived and led a year-long

series of webcasts hosted by Federal Publications Seminars with foreign law

firms regarding contracting in their countries.


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.

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)
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.
Register Now for:
ITAR Compliance: A Voluntary Disclosure and Best Practices Workshop
close window
By Phone
Call (888) 494-3696