Compliance Programs

The Core Elements of a Compliance Program

The Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Controls (DDTC) both have guidelines of what should be included in a compliance program.

DDTC suggest a comprehensive compliance program includes the following elements:

  • Organizational Structure;
  • Corporate Commitment Policy;
  • Identification, Receipt and Tracking of ITAR Controlled Items/Technical Data;
  • Re-Exports/Retransfers;
  • Restricted/Prohibited Exports and Transfers;
  • Recordkeeping; and
  • Training
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Benefits of a Compliance Program

There are many benefits of establishing and/or improving your business’ Compliance Program. Two such reasons include:

  • A compliance program outlines your expectations on how your import and export transactions must be handled, reducing the chance of violations;
  • A compliance program can be a mitigating factor for reducing penalties if your company violates the regulations.