Empowered official (eo)
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As the Empowered Official (EO), of this arms manufacturing company, it is my responsibility to advise and support senior management on the laws and regulations that must be followed for import, export, and customs. All of these activities fall under the jurisdiction of International Traffic in Arms Regulation (ITAR). The impact of ITAR, on our company, will be to organize training, perform audits and maintain record keeping in order to prevent information transfer to unauthorized persons.
The scope of ITAR is to control the arms proliferation, to protect US interests (both commercial and national security) and to protect the interests of US allies. This means we must protect technical information about defense articles and defense services handled by our company. A defense article is any item or technical data designated in the United States Munitions List (USML). If a product which our company manufactures is a defense article which appears on the USML, we are responsible for ensuring that no technical data (either recorded or stored in physical forms such as models, mockups, etc.) directly relating to the item is divulged to foreign persons whether in the United States or abroad. Additionally, any defense service directly related to the defense article is also protected by ITAR. This means that any training or technical data (design, development, engineering, production, assemble, testing, repair, maintenance, modification, operation, demilitarization, destruction, processing, etc.) directly related to the article should not be divulged to foreign persons. However, product marketing information concerning the purpose, function, or general system descriptions is not protected by ITAR as long as it does not include technical information
A special category of defense articles are significant military equipment, which require special export controls because of their capacity for substantial military utility or capability. In order to determine whether our company is manufacturing significant military equipment, we must check if these items are preceded by an asterisk in the USML. A subset of significant military equipment is the major defense equipment. The difference being that major defense equipment are the items having a nonrecurring research and development cost of more than $50,000,000 or a total production cost of more than $200,000,000.
In summary, any defense article or defense service which our company handles will be governed by ITAR regulations. This means we must maintain accurate records of these items, and ensure all of our staff members are aware of these specials controls which govern these items. Additionally, significant military equipment and major defense equipment follow special export controls of which everyone needs to be aware in order to prevent information, which could compromise US commercial or national security, from falling into foreign hands. Failure to follow ITAR regulations could result