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International Traffic in Arms Regulations, or ITAR is an important section of regulations under Title 22 of the Code of Federal Regulations. ITAR regulations focus on the import and export controls for products and services which are defense related. These regulations are yet another layer of our nations network dedicated to the protection of US national security and foreign policy.
Typically, products and services subject to ITAR regulations are military products and services. However, the line between military products and services and commercial products and services has blurred. This is true because of the endless list of technologies that began as military and were incorporated into our everyday commercial usage products. This graying of the lines can make it more difficult to determine applicability. Items appearing on the USML (U.S. Munitions List) will be subject to ITAR regulations. Defense services will be subject to ITAR regulations. Some technical data and software will be subject to ITAR regulations.
When products, services and technical data are subject to ITAR regulations, it is imperative to realize that these items CANNOT be exported in the conventional sense. Exporters of items subject to ITAR regulations must first register with the U.S. Department of State. Additionally, an export license MUST be obtained for any items appearing on the USML.
Note that failure to be in compliance with ITAR regulations can be catastrophic to companies. The nature of these violations leads to rather extreme penalties at the disposal of the enforcement community. Criminal violations can lead to 10 years imprisonment and up to $1,000,000.00 per violation. Because of this, it is extremely important for US companies to understand whether their products, services and technical data/software is subject to ITAR regulations.
JAS USA Compliance Team is well versed in ITAR regulations. Our experience in supporting our own internal vertical JAS GLS (Government Logistics Services) has allowed us to be on the cutting edge of this niche market sector. Need help? Contact us today!
For December, we are highlighting Jeffrey Bispham on the West Coast! Jeff has been in the industry for 26 years and remembers using a typewriter to prepare 7512's. He has always worked in the import/customs brokerage side of logistics. Jeff was adopted as part of the JAS Family when JAS acquired Tigers back in 2021 where Jeff had long tenure.
In October 2023, the JAS Forwarding (USA) Tacoma Foreign Trade Zone became an active FTZ in the JAS USA Network. Jeff became the FTZ administrator of that site and has been instrumental in building the compliance for our FTZ site on the West Coast.
Jeff enjoys all sports, although he would tell all that he has become more of a spectator than a player as the years have passed. Jeff enjoys being outdoors. But most of all, he enjoys spending time with his family. That time can often occur at the beach, or a Seattle sporting event (Mariners, Seahawks and Kraken).
Jeff is yet another great example that People Make the Difference!
In November, JAS USA Corporate Compliance team members teamed up with JAS Atlanta Branch team members to facilitate client compliance training. From left to right, Calvin Oh (Corporate Compliance), Scott Cassell (Corporate Compliance), Carlo Rebuffi (Manager of Live Animals Division-ATL), Laurie Arnold (VP Corporate Compliance), and Rishma Patel (CHB Manager-ATL). The team was able to facilitate learning on the topic of import compliance.
OFAC (Office of Foreign Assets Control), part of the Department of Treasury, has imposed a $1.1 Million penalty on a US individual. The panlty was issued for 75 violations of OFAC Iran sanctions.
To read the full details check out the link below:
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