A telecommunications equipment manufacturer with facilities in several countries faced a tough challenge after it became apparent that their advanced VLF communication modem designs fell under the ITAR’s purview. ITAR compliance meant only U.S. persons would access the VLF modem’s designs. Designs from overseas facilities had to be shipped into a facility within the U.S. where U.S. persons could integrate the work into the VLF modem design and build process. The manufacturer contracted Cleared Systems to assess its desktops, servers, network, products, and laptops for any ITAR-controlled components or data.


  • Protect Confidentiality of ITAR-Controlled data:  To implement mechanisms that ensure the manufacturer’s ITAR-controlled data can only be accessed by an authorized person and only after reaching their security boundary.
  • Enhance Data Visibility and Forensic Traceability: Implement measures to provide the manufacturer with improved visibility into all data movements within the network and establish a robust forensic trail that offers concrete evidence demonstrating that only U.S. persons access or view ITAR-controlled data, thereby enhancing accountability and compliance. 
  • Implement Comprehensive ITAR Training: To provide extensive training to all employees involved in the handling, marking, and management of ITAR-controlled data, environments, and components.
  • Facilitate Internet Access with Stringent Controls: To allow internet access to the manufacturer’s full resources within every facility while applying stringent controls. 
  • Granular Access Control for Design Data: Enable any user from any machine to access design data while applying appropriate policies at the individual component level within files or documents.


  • Workforce Segmentation and Productivity Impact: Achieving ITAR compliance by segmenting the workforce to ensure that only U.S. persons had access to the VLF modem designs profoundly impacted worker morale and productivity. Limiting access based on citizenship created divisions within the company employees, decreasing overall productivity and employee satisfaction. 
  • Competitive Market Pressures: The telecommunications equipment market is highly competitive, with rapid time-to-market being essential to retaining market share. The ITAR compliance process raised concerns that competitors could gain a competitive edge while the company focused on aligning with ITAR requirements. The fear of losing customers and profits added further pressure to the compliance efforts. 
  • Data Reclassification and Supplier Issues: The manufacturer was compelled to reclassify their data due to ITAR restrictions. This process led to internal disruptions and external challenges, particularly with suppliers needing to align with ITAR compliance. Some suppliers even terminated contracts with the manufacturer due to these complexities, leading to supply chain disruptions and financial setbacks. 
  • Secure Collaboration and Complex Relationships: The manufacturer needed a secure platform for collaboration between their employees, suppliers, and end-users in various facilities and even different locations. Simultaneously, they had to ensure the rigorous protection of ITAR-controlled components from access by non-U.S. citizens. The intricate web of ITAR restrictions complicated relationships between these parties, introducing barriers to effective collaboration and potentially impacting operational efficiency. 


  • Our team implemented auditing, monitoring, and logging on the manufacturer’s systems to track data access and provide reporting. This would give the manufacturer greater visibility into all data movement within their network. It would also establish a robust forensic trail that offers concrete evidence, demonstrating that only U.S. persons access or view ITAR-controlled data, enhancing accountability and compliance.
  • Cleared Systems automatically classified, marked, and reported on the presence of ITAR-controlled data and components in the manufacturer’s premises. We applied a Masking policy to obfuscate ITAR-controlled data and components from non-U.S. persons while allowing complete visibility of other fields and components.
  • We deployed cryptographic modules compliant with FIPS 140-2 or other compliant encryption, rights management controls, and data loss prevention mechanisms to secure data, whether at rest or during transmission between authorized parties. This ensured that Data is end-to-end encrypted whenever in transit.
  • To ensure compliance with ITAR regulations and secure technical data, we divided the manufacturer’s network infrastructure into separate segments with controlled boundaries. We also implemented strict internet access controls through a robust proxy filter, including content and application-level controls. Additionally, our team deployed real-time monitoring and logging of network activities, user behavior, and data access for prompt detection and response to compliance breaches.
  • Cleared System’s extensively trained the employees involved in handling, marking, and managing ITAR-controlled data, environments, and components. We also entered a contract with the manufacturer to develop and continue offering tailored ITAR compliance to all the manufacturer’s employees regardless of their level. This would ensure that all personnel are well-versed in ITAR compliance requirements, fostering a culture of awareness and responsibility within the organization.


  • Enhanced data security and ITAR compliance: By deploying end-to-end encryption, rights management controls, and data loss prevention mechanisms, the manufacturer successfully protected the confidentiality of ITAR-controlled data. This ensured that only authorized individuals could access the data and guaranteed compliance with ITAR regulations. The stringent data security measures put in place significantly reduced the risk of unauthorized data exposure or breaches while improving the manufacturer’s ITAR compliance efforts.
  • Improved accountability and traceability: By implementing auditing, monitoring, and logging measures, the manufacturer gained greater visibility into all data movements within their network. This resulted in a robust forensic trail that provided concrete evidence, demonstrating that only U.S. persons accessed or viewed ITAR-controlled data. Enhanced visibility and traceability significantly improved accountability and compliance adherence, strengthening ITAR compliance.
  • Productivity maintenance: Despite the challenges related to workforce segmentation, the manufacturer managed to maintain operational productivity. The workforce was able to adapt to the ITAR compliance requirements without significant disruption, thereby ensuring that productivity remained relatively stable.
  • Retained the manufacturer’s competitive edge: While ITAR compliance is rigorous, the manufacturer successfully retained its competitive edge. Rapid time-to-market was sustained, and concerns about losing customers and profits to competitors were mitigated, helping the company maintain its market position.
  • Culture of security and accountability: Contracting us for extensive ITAR training enabled the manufacturer to cultivate a data security and accountability culture. Employees at all levels became well-versed in ITAR compliance, promoting heightened data security awareness and reducing the risk of inadvertent violations. The workforce’s increased accountability reinforced the company’s commitment to ITAR compliance.