Course Summary:
This course provides learners with the advanced-level training they need to perform their role as an empowered official under ITAR 120.67 and to understand the implications of that role in the context of their organization's ITAR compliance posture. The course includes training on key activities and definitions within the trade compliance environment; the use, application process, and management of authorizations under both the ITAR and EAR; assessing and managing risk; disclosing violations; and recordkeeping.
The content in this course aligns with the Tier 4 requirements outlined in Element 5 of the DDTC ITAR Compliance Program Guidelines and can be supplemented with the organization-specific content recommended in the guidelines, including:
- Details about an organization's ITAR Compliance Program;
- The future needs of the organization, including mergers, acquisitions, or divestitures, development of new product lines, and expansion into a new region of the globe; and
- New developments in U.S. foreign policy.
In addition to the course content, learners will get a year of free access to the Webinar Series for Trade Practitioners, certification from the Schar School of Policy and Government at George Mason University, and a year of regulatory course updates.
Learning Objectives:
After taking this training, learners will:
- Develop a holistic understanding of their role in their organization as an empowered official and the implications of that role in the context of their organization's ITAR compliance posture.
- Be able to identify when an export occurs, which authorization applies to the export, how to obtain the authorization, and how to manage the life cycle of the authorization after approval (i.e., recordkeeping and reporting, decrementing value, amendments, etc.).
- Understand how to properly identify and disclose ITAR violations and develop and implement corrective actions to address the causes of the violations.
- Be able to identify the steps to develop and maintain a healthy ITAR Compliance Program within their organization and ensure employees in other departments understand their roles as they apply to ITAR compliance. Develop baseline knowledge of EAR requirements and compliance. If, in addition to being responsible for ITAR compliance, learners are responsible for commercial exports within their organization, they should receive additional training on EAR compliance.
Target Audience:
Empowered officials
Course Outline:
- Introduction to U.S. Export Compliance for Empowered OfficialsThe Arms Export Control Act
Layout of the ITAR
DDTC Registration
The Export Control Reform Act
Other Statutory Provisions, Executive Orders, and Presidential Documents
How the EAR is Structured - Jurisdiction and Classification OverviewFormal Commodity Jurisdiction Requests
Elements of a CCATS Request
Encryption Items
Introduction to the Order of ReviewIdentifying Technical Information
What is ITAR Technical Data?
Marking Technical Information
Other Jurisdiction and Classification Considerations
Triggers, Tips, and Common MistakesDocumentation and Reassessment
- An Introduction to Activities Regulated by the U.S.ITAR §120.67: Empowered Official
Overview of End-Use and End-User Considerations
Types of Items and Activities Regulated by the U.S.
Restricted/Denied Party Screening
Foreign Military Sales and Direct Commercial Sales
Technology Security and Foreign DisclosureMergers, Acquisitions, and Divestitures
- Introduction to EAR and ITAR AuthorizationsITAR Licenses
Overview of Part 124 Agreements
Reconsideration of Provisos
U.S. Persons Employed Abroad
ITAR Exemptions
Overview of ITAR License Exemptions
Summary of the Congressional Certification Requirement
Brokering: An Introduction
Department of State Approvals
Routed Export Transaction
Department of State Submission Portals
Tips for SubmissionReview of Approved Authorization
Complying with License Provisos and Limitations and License Conditions
Questions Regarding ITAR Provisos
Tracking of Activities
DSP Amendments
Part 124 Agreement AmendmentsIntroduction to ITAR Recordkeeping and Reporting
ITAR Recordkeeping Requirements
Reports Required by the ITAR
Certification Requirements for Exemptions
Reporting on Exports of ITAR Technical Data and Defense Services
Recordkeeping for Political Contributions, Fees, and Commissions
Destination Control Statements
Post-Approval Activities for Part 124 AgreementsPolitical Contributions, Fees, and Commissions
Definitions
Information to Be Furnished
Introduction to EAR Recordkeeping and ReportingBest Practices for Authorization Management
- Export Clearance OverviewAn ITAR Example: Exemption 123.4
Electronic Export Information
Tracking
Decrementation Under the ITAR
Hand Carrying Hardware
Variances in Outgoing and Incoming Authorizations
Domestic Transactions with Foreign Persons - Trade Compliance Programs Overview
Regulatory Guidance on Elements of an Effective Trade Compliance Program
Topics to be Addressed in Trade Compliance Program
Developing and Managing an Export Compliance Program–focus on updates for new guidelines
Investigations and How to Perform Root Cause AnalysisIdentifying and Disclosing Potential Violations
What Constitutes a Violation Under the ITAR?
Penalties for ITAR Violations
Voluntary Disclosures of ITAR Violations to the U.S. Department of State
Filing a Voluntary Disclosures Under the ITARWhat Constitutes a Violation Under the EAR?
Penalties for EAR Violations
Voluntary Self-Disclosure of EAR Violations to BIS
Identifying When a Disclosure Should be MadeTracking Implementation of Corrective Actions
Compliance and Enforcement Actions
Debarment/Ineligibility Status
Industry/Peer Best Practices for Trade Compliance Programs
Scenario: The EagleWing 4700 Tactical Unmanned Aerial Vehicle
Scenario: Collaborating With a Swedish Company On a Laser-Guided Rocket
Scenario: Brokering a Military Aircraft
Scenario: An FMS Contract with Nonexistentstand
Conclusion
The final evaluation consists of 50 True/False or Multiple-Choice questions with a requirement of at least 80% correct to pass.
Ready to strengthen your supply chain team?
Certificate of Course Completion from
Continuing Education
LCB/CES Credits: 5.5
Real Clients. Real Teams. Real Results.


Herman Savenije
The individualized learning plans, based on a pre-assessment, enable optimal learning success.


Lindsay Jett
Skill Dynamics gives team leaders a lot of flexibility to develop each of their team members in their specific areas, or grow into new ones.


Stefan Menziger, CEO
Skill Dynamics provides exactly what is needed in the world’s changing environment.