Compliance Program Guidelines Issued By DDTC

On December 5^th, the Department of State's Directorate of Defense Trade Controls (DDTC) issued new Compliance Program Guidelines (CPG) intended to provide an overview of an effective compliance program.

The CPG is broken down into elements covering the spectrum of ITAR compliance from company management commitment, registration, jurisdiction and classifications, authorizations, recordkeeping, violations, training, risk assessment, and audits and compliance monitoring.

In the introduction, DDTC states, "The purpose of an ITAR Compliance Program (ICP) is to establish robust policies and procedures to ensure that organizations and their staff who engage in ITAR-controlled activities do so in compliance with the ITAR, Title 22 of the Code of Federal Regulations in parts 120- 130, issued pursuant to the Arms Export Control Act (AECA) (22 U.S.C. § 2751 et seq.), as amended. Operating an effective ICP helps organizations integrate ITAR requirements into their business