Evaluate the nature of the business and identify any ITAR related aspects
Identify all controlled technical data within the organization
Approval: Identify Controlled Technical Data
Designate a compliance officer responsible for ITAR
Develop an internal ITAR compliance plan
Implement strict controls on access to controlled technical data
Train all employees on ITAR regulations and compliance requirements
Document procedures for dealing with ITAR violations
Conduct routine audits to ensure continued compliance
Approval: Routine Audit Results
Create procedures for responding to request for controlled technical data
Identify all non-US persons within the organization
Review and update the company's export controls program
Establish and maintain ITAR recordkeeping process
Continuous monitoring and updating the compliance program
Approval: Compliance Program Updates
Implement security measures to ensure ITAR compliance
Ensure regular risk assessments and audits
Train and educate staff on the importance of ITAR compliance
Maintain registration with the Directorate of Defense Trade Controls
