An ITAR compliance program is a structured set of policies, procedures, and controls that ensures your organization meets all requirements under the International Traffic in Arms Regulations (22 CFR 120–130). A complete program includes a Technology Control Plan (TCP), USML classification procedures, export licensing processes, deemed export controls for foreign national access, a 5-year record-keeping system, voluntary disclosure procedures, annual self-assessments, and a designated Empowered Official with authority to bind the organization on all export control matters.
Program Foundation
DDTC registration is the gateway to lawful defense trade — but registration alone does not make you compliant. DDTC expects every registrant to maintain a functioning compliance program that prevents unauthorized exports, controls access to technical data, and ensures all defense trade activities are properly authorized and documented. Without a documented program, you are operating on good intentions rather than defensible controls.
An ITAR compliance program is not a binder that sits on a shelf. It is a living operational framework that touches hiring, facility access, IT security, engineering workflows, shipping, procurement, and business development. When built correctly, it integrates seamlessly into your existing operations. When built poorly — or not at all — it exposes your organization to civil penalties up to $1,267,619 per violation, criminal penalties up to $1,000,000 and 20 years imprisonment, debarment from defense trade, and loss of contracts. The cost of building a compliance program is a fraction of the cost of a single violation.
Program Components
Every comprehensive ITAR compliance program must address these eight foundational elements. We build each one tailored to your organization’s size, operations, and risk profile.
The cornerstone of your compliance program. Your TCP defines physical security controls, IT security measures, visitor management procedures, foreign national access restrictions, data marking requirements, and disposal protocols for ITAR-controlled materials. We build TCPs that are operationally practical — not just legally sufficient.
Systematic procedures for classifying your products, services, and technical data against the United States Munitions List (USML). Includes commodity jurisdiction (CJ) request processes for items that may fall under ITAR or EAR, classification documentation templates, and periodic re-classification reviews when products or regulations change.
Documented procedures for determining when an export license is required, selecting the appropriate authorization type (DSP-5, DSP-73, TAA, MLA), preparing and submitting applications through DECCS, tracking license provisos, and managing license modifications and renewals. Includes exemption screening under 22 CFR 125.4 and 126.4.
Procedures for managing deemed exports — the release of ITAR-controlled technical data to foreign nationals within the United States. Includes foreign national screening and tracking, visual and physical access controls, Technology Control Plan provisions specific to foreign person access, and exemption documentation for fundamental research and public domain exceptions.
Under 22 CFR 122.5, all ITAR registrants must maintain records of defense trade activities for a minimum of 5 years. We implement structured record-keeping systems covering license files, shipping documentation, technical data transmittals, training records, classification determinations, and all DDTC correspondence. Records must be retrievable, auditable, and protected against unauthorized modification.
Under 22 CFR 127.12, DDTC strongly encourages voluntary self-disclosure of known or suspected violations. Your compliance program must include clear procedures for identifying potential violations, conducting internal investigations, making timely disclosures to DDTC, and implementing corrective actions. Voluntary disclosure is a significant mitigating factor in DDTC’s penalty determinations.
Systematic annual reviews of your entire compliance program to verify that controls are functioning, records are current, training is up to date, classifications remain accurate, and all defense trade activities are properly authorized. Self-assessments identify gaps before they become violations. Many prime contractors require subcontractor self-assessment documentation as a contract condition.
Under 22 CFR 120.67, your Empowered Official has authority to sign license applications, verify compliance, and bind the organization. We help define the role, draft the designation letter, establish the EO’s oversight responsibilities, and build the support structure (compliance team, reporting lines, escalation procedures) that enables the EO to fulfill their obligations effectively.
TCP Development
The Technology Control Plan (TCP) is the most operationally significant document in your ITAR compliance program. It translates regulatory requirements into concrete, day-to-day security procedures that your workforce can follow. A well-crafted TCP protects controlled technical data and defense articles from unauthorized access — whether the risk comes from foreign national employees, visiting contractors, cyber intrusions, or careless handling of sensitive materials.
DDTC does not prescribe a standard TCP format, which means organizations must build plans tailored to their specific operations, facility layouts, workforce composition, and data environments. This flexibility is both an opportunity and a risk — a well-designed TCP integrates seamlessly into your operations, while a generic or poorly implemented plan creates compliance gaps that may not surface until an audit, incident, or enforcement action.
TCP & Cloud Computing
Many organizations underestimate the ITAR implications of cloud-based systems. ITAR-controlled technical data stored on cloud servers must be protected from access by foreign persons — including the cloud provider’s own staff. Your TCP must address cloud service provider selection, server location verification, encryption key management, and contractual obligations ensuring ITAR compliance across the cloud infrastructure.
People & Training
Even the best-designed compliance program fails without the right people executing it. Your Empowered Official (EO) is the designated authority under 22 CFR 120.67 who signs license applications, certifies compliance, and takes personal legal responsibility for the accuracy of all DDTC submissions. Beyond the EO, every employee with access to ITAR-controlled items or data must understand their compliance obligations — ignorance is not a defense under ITAR.
We develop complete training curricula tailored to your organization’s operations, including presentation materials, knowledge assessments, and record-keeping templates. Training is delivered in formats appropriate for your workforce — from classroom instruction for core compliance staff to brief awareness modules for general employees. All training content is updated annually to reflect regulatory changes and lessons learned from self-assessments.
Our Approach
Our compliance program development follows a structured methodology: we assess your current state, identify gaps against regulatory requirements, build the documentation and procedures to close those gaps, train your team, and establish the ongoing assessment framework to keep the program current. Every program we build is tailored to your operations — not a template with your name on it.
About the Author
Jared Clark is the founder of Certify Consulting and has guided 200+ organizations through regulatory compliance engagements spanning ITAR, ISO, FDA, and GMP requirements. With a Juris Doctor providing legal framework expertise, an MBA for compliance strategy, PMP for structured implementation, and CMQ-OE for organizational excellence, Jared brings a uniquely comprehensive perspective to ITAR compliance challenges.
His ITAR practice focuses on compliance program development, DDTC registration, USML classification, export licensing, Technology Control Plans, training, and voluntary disclosure support for defense contractors across the U.S. defense industrial base.
Common Questions
Answers to the most common questions about building an ITAR compliance program. See full ITAR FAQ →
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