The Mil & Aero Blog
Thursday, March 13, 2008
  Think you have an ITAR issue? Protect yourself, experts say

Posted by John Keller

Component suppliers who even suspect that their products might be designed into military systems need to take steps to protect themselves from potential violations of International Traffic in Arms Regulations (ITAR). If they don't, they risk serious trouble.

I'm not talking about just fines; I'm talking about losing your company. The bottom line is protecting yourself. This is risky -- to the point that in extreme circumstances you could be working at Wendy's the next day, warns Dean Young, facilities security officer for Celestica Aerospace Technologies in Austin, Texas.

Young made his comments Wednesday in a panel discussion at the Military & Aerospace Electronics Forum (MAEF) conference and trade show in San Diego, which concluded Wednesday afternoon.

Component suppliers should be on guard for ITAR issues, particularly if they are doing business with the large prime defense contractors. Most of these large companies have ITAR organizations in place to help their suppliers navigate often-treacherous ITAR waters, but sometimes problems can occur, experts admit.

Prime defense contractors are very sensitive about releasing details about whose products they are using, and in which applications -- sometimes to the degree that individual engineers or program managers inside these companies might be reluctant to tell even the suppliers of the components where these devices are going.

If this happens, push back and get enough information to protect yourself, panelists told MAEF attendees. Don't accept "we're not telling," or "mind your own business," from customers -- ever.

If that kind of thing happens, such as if a person at a prime contract is being difficult or is overly concealing information, "I would like to know about it," says Karen Jones, director of export import operations at Raytheon Missile Systems in Tucson, Ariz.

In addition to Young and Jones, other panelists were Kay Georgi, partner at the law firm of Arent Fox LLP in Washington, and Lawrence Fink, director of corporate export administration at Science Applications International Corp. (SAIC) in San Diego.

Component suppliers need to get smart about ITAR guidelines; they need to get smart fast before they get into trouble. It can be a matter of protecting yourself, your family, and your company.

It may even involve the potential of walking away from revenue if a supplier simply cannot get the information he needs to protect himself, experts say.

At the same time, suppliers should be as tactful and as partnering as possible when they approach their prime-contractor customers so they don't risk killing their business or relationships.

For more information, panelists recommend a pamphlet on Project Shield America from the U.S. Department of Homeland Security's investigative bureau of Immigration and Customs Enforcement (ICE) in Washington.

Project Shield America is an industry outreach program to prevent the illegal export of sensitive U.S. munitions and strategic technology to terrorists, criminal organizations, and foreign adversaries.

To learn more about the Project Shield America pamphlet, contact ICE online at www.ice.gov.
 
Comments:
Doesn't the prime contractor have the prime responsibility for Export Control? So, if I purchase an ITAR item from a vendor, integrate it into a system, deliver the product in contravention to the ITAR, they can come back and slam the vendor? That seems so wrong in so many ways. Yes, slam me and the company I work for, but not the folks delivering parts within the law. That would be the same as the feds charging Winchester with accessory to murder because they made the bullet that killed somebody.
 
Interesting article and as an electronic components distributor we run into this routinely. We often ask the primes to complete an end user certificate, particularly if the part has a military or dual use application. In most cases, they understand why we are asking for this info and it is rarely an issue. I would be hard pressed to even remember ever losing an order over it. Keep up the good work,
http//www.lasdefense.com
 
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