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Any Research Laboratory, University, corporation, or any other form of organization within the U.S. dealing with furnishing defense services, manufacturing, or exporting defense items must register with DDTC and comply with ITAR. Unauthorized export of any of the items listed in the USML (United States Munitions List) could result in hefty penalties.

There are over 13000 universities, research labs, and defense companies handling military and defense technologies. If they are ITAR compliant, they should only share the USML listed items with persons in the U.S. unless otherwise authorized. To Become ITAR compliant, secure data storage and transmission are vital, and Microsoft GCC High plays an important role. So, what is ITAR, and how can you become ITAR compliant? Read on to learn all about International Traffic in Arms Regulations.

What is ITAR?

ITAR refers to a set of regulations instituted and administered by the State Department to control exportation and importation of military and defense-related technologies on the USML. ITAR aims to control the access of the technologies listed in the United States Munitions List and any data associated with them. Therefore, any organization dealing with USML technologies must securely store and transmit its data.

How Can You Achieve ITAR Compliance?

To date, there is no formal process of certification to be ITAR certified or ITAR compliant. Organizations are expected to understand and comply with the regulations on their own. However, there are three vital steps that prime and subprime contractors can take to become compliant with the regulations and demonstrate their ITAR readiness.


The first step that any company dealing with military and defense artifacts should take is registering with the DDTC (Directorate of Defense Trade Controls) as per ITAR part 122.

ITAR Compliance Program

Adopting internal written procedures and policies is the next step in learning the ITAR general requirements­. The State Department recommends this for organizations dealing with ITAR controlled activities. If such a company has an ITAR violation, the State Department may reduce the penalties. A compliance program shows that your organization has instituted a formal process of becoming ITAR compliant and projects a complex approach towards solving the problem.

Ensuring Cloud Data Storage and Transmission is ITAR Compliant

After registering with DDTC and undertaking an ITAR Compliance program, the next step is ensuring cloud data security. You must ensure that the technical data isn't distributed or shared with foreign nations and persons. Microsoft has several tools like Microsoft 365 DOD and Microsoft GCC High to ensure that your information is safe on the cloud. These cloud platforms ensure you remain compliant while dealing with sensitive, unclassified, and classified information. Microsoft GCC is also vital at meeting CMMC certification.

However, ITAR data is an instance of CUI. Therefore, all the baseline data protections for CUI basic also apply to the International Traffic in Arms Regulations. When you've put the baseline protections in place, CUI-specific requirements are added to the list of controls. If your organization deals with ITAR data and has contracts with DOD, you need to understand DFARS, CMMC 2.0 (mainly level 2), and CUI requirements.

What Are the Penalties For Non-Compliance With ITAR?

The State Department imposes heavy penalties for ITAR violations or non-compliance, including criminal fines, civil fines, and up to 10 years in jail per violation or instance. At worse, the United States Government can ban your corporation from future importation or exportation activities.

For instance, FLIR Systems, Inc was fined civil penalties amounting to $30 million by the State Department for transferring USML information to dual nationality employees. The company was also required to hire a third-party official to oversee the agreement and implement better compliance measures. Therefore, ITAR compliance is vital, and you should do anything possible to remain compliant.

How is ITAR Data Secured?

Because of the ITAR violation Penalties, protecting its data with as many security layers as possible makes sense. Since ITAR is a Federal regulation, following their guidelines for data security is a vital step. These guidelines and standards are defined in the NIST SP 800-53. To secure your ITAR data, Discover and classify all the sensitive data, map permissions and data, monitor access control, monitor the data, user behavior, and file activity. You can achieve all this with Microsoft Azure Information Protection.

If you deal with any artifact on the USML, you should check whether you are ITAR compliant. Since ITAR is a part of CUI, it seems reasonable to ensure you are CMMC compliant first. These include migrating to Microsoft GCC High for on-cloud data storage and transmission. There are many repercussions of dealing with Military and defense artifacts listed in the United States Munitions List without ITAR compliance. To learn more about Microsoft GCC High and ITAR Compliance, visit our website today.

Carl B. Johnson
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