Your ITAR Obligation Doesn’t Wait for You to Be Ready
If your organization handles defense-related technical data, hardware, or services covered under the United States Munitions List, you have ITAR obligations right now — whether or not anyone has built a compliance program around them. We build that program.
- Fixed-Scope Engagement
ITAR engagements are scoped individually. Every engagement starts with a conversation, not a fixed price.
WHY THIS CAN’T WAIT
CMMC Non-Compliance Costs You a Contract. ITAR Non-Compliance Can Cost You More.
The International Traffic in Arms Regulations carry criminal penalties for violations — not just contract consequences. Unauthorized export of controlled technical data, hardware, or services on the United States Munitions List can result in civil fines and criminal prosecution.
⚠️ Federal Enforcement Matter:
ITAR violations are not a compliance gap you fix with a corrective action plan. They are a federal enforcement matter. The time to build your compliance program is before an audit, an acquisition, or an export enforcement inquiry makes it urgent.
HOW MOST ENGAGEMENTS BEGIN
It Usually Comes Up During a CMMC Conversation
The most common entry point for our ITAR engagements isn’t an ITAR inquiry — it’s a CMMC scoping conversation. We’re mapping CUI data flow, walking through who handles what technical data, and someone mentions they also do ITAR work. Then we start asking questions.
What we find almost every time: the organization has real ITAR obligations and controlled technical data moving through their environment — with little or none of the compliance infrastructure in place. No Empowered Official on record. No Technology Control Plan. No documented data flow.
CMMC Overlap Note:
ITAR and CMMC have significant overlap — the same technical data, the same people, the same systems. We structure engagements to cover both simultaneously so you’re not paying for the same scoping and data flow work twice.
- THE ITAR COMPLIANCE PROGRAM
The Infrastructure Your Organization Needs to Manage ITAR
01
Empowered Official (EO)
ITAR requires every registered organization to designate an Empowered Official — a senior person with the authority to sign export licenses and make binding compliance decisions. We define the role, document the designation, and make sure the person holding it understands their responsibilities.
02
ITAR Compliance Officer (ICO)
Someone needs to manage day-to-day ITAR compliance — tracking what’s controlled, who has access, and what’s been exported. We define the scope of responsibility and document it so it’s owned by a specific person, not shared by everyone and owned by no one.
03
ITAR Data Flow Mapping
We map what happens to your controlled technical data from the moment it enters your organization to the moment it’s destroyed or returned — entry, at rest, handling, and flowdown to subcontractors and vendors.
04
Technology Control Plan (TCP)
The TCP is the governing document of your ITAR compliance program. It defines your controlled articles, your access control framework, your foreign national access procedures, your training requirements, your incident response process, and your recordkeeping obligations. We build this specific to your organization — not a generic template filled in with your name.
05
Policies and Procedures
We write the policies and procedures that govern how your organization handles controlled technical data day to day — access control, marking and handling, visitor and foreign national procedures, incident reporting, and records retention. Every policy is mapped to the specific ITAR requirement it satisfies.
06
Training
We build and deliver training specific to your environment and your team — so the people in scope understand their obligations in practical terms, not theory.
OUR LANE AND YOUR ATTORNEY’S LANE
We Build the Program. Your Attorney Advises on Jurisdiction and Licensing.
There are two distinct bodies of work in ITAR compliance. The first is building and running the compliance program — roles, controls, documentation, data flow, policies, training. That’s what we do.
The second is legal interpretation — determining whether specific items or data fall under ITAR jurisdiction, advising on export license requirements, and providing legal opinions on classification. That belongs with a qualified export attorney.
Efficient Legal Collaboration:
Clients are better served — and attorneys work more efficiently — when the compliance program infrastructure already exists before the legal conversation starts. You shouldn’t be paying attorney rates to figure out who your Empowered Official is.
ENGAGEMENT STRUCTURE
Every ITAR Engagement Starts With a Conversation, Not a Price Sheet
ITAR compliance programs are scoped individually because the variables matter: what you manufacture, what contracts you hold, how many people are in scope, whether foreign national access is a factor, and whether you’re building from zero or have existing documentation.
The initial scoping conversation typically runs 60 to 90 minutes. You walk away with a clear picture of what you have, what you’re missing, and what a program build would involve.
If you’re already engaged with us on CMMC, the ITAR scoping conversation is usually shorter — we already know your environment and data flow. The overlap means the program build is faster and less expensive than two separate engagements from scratch.
IS THIS YOU?
This Service Is For Organizations That:
- Manufacture or handle hardware, components, or technical data covered under the United States Munitions List
- Provide defense-related services under DoD contracts or subcontracts
- Have employees or contractors who are foreign nationals with access to controlled technical data
- Export — or plan to export — controlled articles, technical data, or defense services
- Know they have ITAR obligations but have never built a formal compliance program around them
R&D · Defense Manufacturing
They Called About ITAR. They Left With a Full CMMC Program.
A client called us excited — they had just landed a defense contract and an R&D agreement to build a product for the DoD. They wanted help understanding their ITAR obligations. We sat down, walked through our implementation approach, and got to work. Six months later they had a complete ITAR compliance program in place — Empowered Official, Technology Control Plan, data flow documentation, policies and procedures. Leadership was engaged from day one, which made the difference.
But during that process, we reviewed their contract agreements carefully. That’s when we flagged it: they also had requirements under DFARS 252.204-7012, 7019, and 7021. Which meant they had a CMMC obligation they didn’t know about. We walked them through what that meant. Then we built the SPRS baseline, scoped the CMMC program, and took them through implementation. One engagement. Two frameworks. Both done right.
📅 6 Months
🛡️ Itar Compliant
⚙️ CMMC Program Built
- Free Consultation
Start With a Conversation
We’re based in Wichita and work with defense manufacturers, aerospace suppliers, and construction firms across the Midwest — and nationally. If you’re not sure where your ITAR exposure stands, the scoping conversation is the right first step.
No fixed price until we know your scope. No obligation after the conversation.
