2022 ITAR Update

In 2020, V2 Systems became ITAR registered. Back then, we also posted an article about what that means for you as a valued V2 partner. Today we’re giving an updated 2022 refresher on ITAR. This is a brief overview on its primary components, along with an explanation of how your organization can become ITAR compliant.?

And yes, you definitely need to be compliant. There are stiff penalties if you’re not.

What is ITAR?

The International Traffic in Arms Regulations is the United States regulation that controls the manufacturing, sale, and distribution of defense- and space-related articles and services as defined in the United States Munitions List. (This list has been updated for 2022.)

What’s important to note is that it doesn’t just cover physical weapons and military hardware, but also plans, diagrams, photos, and other documentation used to build ITAR-controlled military gear. This is referred to by ITAR as “technical data.” Access to physical materials or technical data related to defense and military technologies is restricted to U.S. citizens only.

Who does ITAR apply to?

Any company that handles, manufactures, designs, sells, or distributes items on the USML must be ITAR compliant. The State Department’s Directorate of Defense Trade Controls (DDTC) manages the list of companies who can deal in USML goods and services, and it is up to each company to establish policies to comply with ITAR regulations. This includes wholesalers, distributors, computer software, and hardware vendors, third-party suppliers and contractors. Essentially, every company in the supply chain needs to be ITAR compliant. If company A sells a part to company B and then company B sells the same part to a foreign power, company A is also in violation of ITAR. This fact alone should demonstrate the importance of V2 Systems being officially registered — and why you need to be compliant as well.

ITAR and Overseas Companies

As stated above, only U.S. citizens can access items on the USML list. This can be problematic for U.S.-based companies with overseas operations, as they are prohibited from sharing ITAR technical data with employees locally hired, unless they gain authorization from the State Department. This rule applies to U.S. companies working with non-U.S. subcontractors, too.

The United States Munitions List

There are 21 categories of “Defense Articles” in the USML. Anything that appears on this list is subject to ITAR regulation.

1. Firearms, Close Assault Weapons, and Combat Shotguns
2. Guns and Armament
3. Ammunition/Ordnance
4. Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs, and Mines
5. Explosives and Energetic Materials, Propellants, Incendiary Agents and Their Constituents
6. Surface Vessels of War and Special Naval Equipment
7. Ground Vehicles
8. Aircraft and Related Articles
9. Military Training Equipment and Training
10. Personal Protective Equipment
11. Military Electronics
12. Fire Control, Laser, Imaging and Guidance Equipment
13. Materials and Miscellaneous Articles
14. Toxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment
15. Spacecraft and Related Articles
16. Nuclear Weapons Related Articles
17. Classified Articles, Technical Data, and Defense Services Not Otherwise Enumerated
18. Directed Energy Weapons
19. Gas Turbine Engines and Associated Equipment
20. Submersible Vessels and Related Articles
21. Articles, Technical Data, and Defense Services Not Otherwise Enumerated

As you can see, that list covers a lot. If you’re not careful, you could miss something and then get hit with a nasty million dollar fine or even prison time. This is especially true for items 17 and 21 which include “articles, technical data, and defense services not otherwise enumerated.” V2 Systems can take that pressure off of you and make sure you’re fully compliant with ITAR. For more information, contact us today for a free consultation.

Since 1995, Manassas Park, VA-based V2 Systems has employed local systems administrators, network engineers, security consultants, help desk technicians and partnering companies to meet a wide range of clients’ IT needs, from research, to implementation, to maintenance. Concentrate on your VISION…We’ll handle the TECHNOLOGY!