International Traffic in Arms Regulations (ITAR) Compliance Policy
Introduction
Cruger Compliance Solutions (a DBA of Cruger Management, LLC) is committed to full compliance with the International Traffic in Arms Regulations (ITAR), as administered by the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC). ITAR controls the export and import of defense-related articles, services, and technical data listed on the United States Munitions List (USML) to ensure national security and foreign policy objectives are met.
Scope
This policy applies to all employees, contractors, clients, and business partners of Cruger Compliance Solutions who handle ITAR-controlled data, articles, or services in any capacity.
ITAR Compliance Commitment
Cruger Compliance Solutions adheres to the following ITAR compliance principles:
- Registration with DDTC: When required, we ensure that all necessary registrations with the DDTC are maintained.
- Controlled Data and Articles: We do not engage in unauthorized exports, re-exports, or disclosures of ITAR-controlled data, articles, or services to foreign persons or entities without proper authorization.
- Access Controls: ITAR-controlled information is restricted to U.S. persons unless specific approvals are granted by the U.S. government.
- Training & Awareness: All relevant personnel receive training on ITAR regulations, compliance obligations, and best practices.
- Recordkeeping: We maintain documentation and records of ITAR-controlled transactions in accordance with regulatory requirements.
- Third-Party Due Diligence: We ensure that all vendors, suppliers, and clients engaged in ITAR-related activities comply with applicable regulations.
- Internal Audits & Reporting: Regular audits are conducted to ensure compliance, and any suspected violations are promptly reported and addressed.
Prohibited Activities
- Exporting ITAR-controlled data, articles, or services without a valid export license or exemption.
- Providing access to ITAR-controlled materials to non-U.S. persons without authorization.
- Engaging in transactions with restricted or prohibited parties as identified by the U.S. government.
- Failing to maintain accurate records and compliance documentation.
Reporting Violations
Any suspected ITAR violations must be reported immediately to the Cruger Compliance Solutions Compliance Officer. Reports can be made confidentially and will be investigated promptly.
Conclusion
Cruger Compliance Solutions takes ITAR compliance seriously and is committed to ensuring that all business activities adhere to the highest regulatory standards. Non-compliance may result in significant legal penalties, including civil and criminal sanctions. Employees, contractors, and partners are expected to uphold these policies and report any concerns regarding ITAR compliance.
For further information on ITAR compliance, please contact our Compliance Officer at [email protected].