Export Control Training. October 2011 Supplier Quality Manager Mike Stone Phone: 252-246-7018. What We’ll Cover Today. Export Basics What is ITAR controlled technical information Who can work on ITAR Programs? What is your Responsibility?. Regulations and What they Control.
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Supplier Quality Manager
U.S. Department of State
Directorate of Defense Trade Controls (DDTC):
- a foreign company/supplier to work on the S80 ITAR program
1. TAA/MLA are specific for individual foreign person or individual foreign company.2. Need specific approval for dual nationals employed at a foreign company.3. Need specific approval when a foreign company sub contracts to another company
- An export is an actual shipment or transmission out of the United States.
- It’s also the transfer of technical data or article to a foreign person or foreign owned company regardless of their location.
Visual inspection that reveals technical data
Conference – AT&T conference/meeting
Hand-carried items – laptops, memory devices
For example – Lili Zhang, US citizen, works for UTRC China.
Blueprints SpecificationsManuals SoftwareTraining Programs Plant ToursElectronic transmissions Technical meetingsPhotographs Instructions
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Technical data does not include information concerning general scientific,
Mathematical, or engineering principles commonly taught in schools, colleges and
universities or information in the public domain. It also does not include basic marketing
information on function or purpose or general system descriptions.
Definition of Public Domain – Information which is published and which is generally
accessible or available to the public:
1. through sales at newsstands and bookstores; subscriptions (without restrictions);
2. at public libraries or from which the public can obtain documents;
3. through patents or published applications available at any patent office (MUST BE AVAILABLE – published, NOT merely submitted patents);
4. through unlimited distribution at conferences, meetings, seminars, where anyone could
5. through public release in any form AFTER approval by the cognizant U.S. Gov’t dept or
6. through fundamental research in science & engineering at accredited institutions where
the resulting information is ordinarily published and shared broadly in the scientific
community. Cannot contain proprietary restrictions or other restrictions such as U.S. Gov’t
access & dissemination controls.
ADDITIONAL GUIDANCE - FOREIGN SUPPLIERS
Export control compliance starts with you.
ITAR and Dept of Commerce controlled information must be indentified and marked