Is My Company Subject to ITAR?

There is an important area of regulation often overlooked by U.S. companies – ITAR.  ITAR stands for International Traffic In Arms Regulations.  ITAR are State Department regulations governing products, technologies and services developed for military use that are most often associated with defense and government contracts firms.  However ITAR frequently extends far beyond these firms to companies in the engineering, communications, manufacturing, transportation, software, chemical, maritime, technical services and other fields.  In light of the broad reach and severe sanctions for ITAR violations (including civil and criminal penalties for companies and their employees), every company should determine if it is subject to ITAR.  The purpose of this Memorandum is to help companies analyze if they are subject to ITAR and the requirements that may apply to them.