1. International Traffic In Arms Regulations (ITAR) For Corporate Officers and Senior Management Compliance Assurance LLC February 16, 2011 Property of Compliance Assurance LLC

2. Property of Compliance Assurance LLC What Are the International Traffic In Arms Regulations? Section 38 of the Arms Export Control Act (AECA) Authorizes the President to Control the Import and Export of Defense Articles and Services Statutory Authority to Promulgate Regulations Was Delegated to the Secretary of State (E.O. 11958) 22 CFR part 120.1 Implements that Authority in the International Traffic In Arms Regulations “The ITAR” Property of Compliance Assurance LLC

3. Property of Compliance Assurance LLC International Traffic In Arms (ITAR) What Exactly is a Defense Article or Service? Part 120.2 – Items designated on the U.S. Munitions List (USML) as specified in part 121 of the ITAR Property of Compliance Assurance LLC Property of Compliance Assurance LLC

5. II – Guns and Armament

6. III – Ammunition/Ordnance

7. IV - Launch Vehicles, etc.

8. V - Explosives, Propellants, Incendiary Agents and Their Constituents

9. VI - Vessels of War and Special Naval Equipment

10. VII - Tanks and Military Vehicles

11. VIII - Aircraft and Associated Equipment

12. IX - Military Training Equipment

13. X - Protective Personnel Equipment

14. XI - Military Electronics

15. XII - Fire Control, Range Finder, Optical and Guidance and Control Equipment

16. XIII – Auxiliary Military Equipment

17. XIV - Toxicological Agents and Equipment and Radiological Equipment

18. XV - Spacecraft Systems and Associated Equipment

19. XVI - Nuclear Weapons Design and Related Equipment

20. XVII - Classified Articles, Technical Data and Defense Services Not Otherwise Enumerated

21. XVIII – Directed Energy Weapons

22. XIX - Reserved

23. XX - Submersible Vessels, Oceanographic and Associated Equipment

24. XXI - Miscellaneous ArticlesProperty of Compliance Assurance LLC Property of Compliance Assurance LLC

25. Property of Compliance Assurance LLC International Traffic In Arms (ITAR) What Exactly is a Defense Article or Service? Part 120.3(a) - “is specifically designed, developed, configured, adapted, or modified for a military application, and Does not have predominant civil applications, and Does not have performance equivalent (defined by form, fit and function) to those of an article or service used for civil application;” Property of Compliance Assurance LLC Property of Compliance Assurance LLC

28. Military training of foreign units and forcesProperty of Compliance Assurance LLC Property of Compliance Assurance LLC

30. If any component is ITAR-controlled, then the equipment on which installed is also ITAR-controlled (see through rule)

31. Purpose for which it is now being used is irrelevant

32. E.g. Military aircraft (C-130) being used for cargo planeProperty of Compliance Assurance LLC

35. Often required part of prime contractor’s programProtects Your Company From Fines, Penalties and Negative Publicity Property of Compliance Assurance LLC

36. Benefits of Not Being ITAR Compliant Joseph Piquet, Port St. Lucie, FL Convicted of 7 counts of conspiracy to export military-use electronic components to Hong Kong and PRC without the required export licenses under the Arms Export Control Act and the International Emergency Economic Powers Act (IEEPA) Submitted false End Use Certificates to the manufacturer (NGC) Sentenced to 5 years in prison Two years supervised release (after prison term) Free Room and Board! Property of Compliance Assurance LLC

37. Senior Management Responsibility Property of Compliance Assurance LLC

39. Officers, addresses/locations, contact numbers

40. Sign Registration Statement and Transmittal Letters

41. Confirm Which Senior Officer Listed on the Registration Statement Will Oversee the Compliance Program

42. Designate and Provide DDTC list of Full-time Employees Who Serve as “Empowered Officials”

43. Provide names and contact infoProperty of Compliance Assurance LLC

44. Senior Management Responsibility Maintain Records of Manufacture, Acquisition and Disposition of ‘Defense Articles and Services’ Maintain Records of Political Contributions, Fees and Commissions Furnished or Obtained Ensure That Managers, Supervisors and Employees Receive Training on AECA and ITAR Requirements Ensure That Employees Understand the Ramifications For Failure to Comply With the Regulations Property of Compliance Assurance LLC

45. Senior Management Responsibility Property of Compliance Assurance LLC And If We Don’t… The Ultimate Responsibility Belongs to Senior Management!

47. Legally empowered to sign license requests or other requests for approval

48. Understands the provisions and requirements or statutes and regulations

49. Has the independent authority to:Inquire into any aspect of a proposed transaction Verify the legality of the transaction and accuracy of info to be submitted Refuse to sign any license application or other request for approval without prejudice or other adverse recourse Property of Compliance Assurance LLC

52. Property of Compliance Assurance LLC What Makes and Effective Compliance Program? An effective export management and compliance program includes adherence to a set of operational compliance policies, procedures, and safeguards AND a written set of export-related guidelines that tell employees what is expected of them and provides management with a framework to evaluate whether: What should happen, does happen and What shouldn’t happen, doesn’t happen …on a daily basis. Source: Bureau of Industry and Security Property of Compliance Assurance LLC Property of Compliance Assurance LLC

53. Property of Compliance Assurance LLC Have Questions? Give Me a Call: www.WeAreCompliant.com Property of Compliance Assurance LLC Property of Compliance Assurance LLC