CAN YOU CHECK YES?
DDTC wants to know about your compliance program.
By Odyssey E. Gray, III
Senior Licensing Associate, FD Associates, Inc.
Over the last two years, the Defense Directorate of Trade Controls (“DDTC”) has advised of its ongoing IT Modernization effort to bring DDTC’s electronic licensing system up to date. The goal is to use current technology to produce a more efficient, informative and user friendly system for exporters. The IT Modernization will be accomplished via a transition from the DTrade electronic (DTRADE) licensing system to the Defense Export Control and Compliance System (“DECCS”). Migration of all existing DDTC data and forms is slated for 2019.
The first form to “go live” is the DS-2032 Registration application, which is expected in the spring of 2019. DDTC has added a question to the DS-2032 form concerning the applicant’s written ITAR compliance program/plan. This is simply a response of YES or NO. DDTC seeks to compile information regarding its registrants’ compliance program status to support its outreach and training efforts and alert them to the importance of having a written ITAR compliance plan/program in place.
This question is a clear indicator that DDTC is aware that many companies do not have compliance plans and programs in place and is placing an emphasis on to learning which registrants fall in that category.
After almost 30 years of assisting clients, we at FD Associates have found that many export violations occur because the client has not invested in developing and documenting their export policies and procedures. Development of compliance plans, programs and procedures can lead to prevention of export violations and ultimately enhance your company’s bottom line by minimizing costs associated with voluntary disclosures and financial penalties.
Don’t be one of those companies that checks “NO” in 2019. FD Associates can provide assistance to your company with the development of compliance plans, manuals and procedures, tailored to the specific needs of small and medium sized companies.