Export Compliance Solutions & Consulting (ECS)

For both the Export Administration Regulations and the International Traffic and Arms Regulations, ECS will work with your engineering staff to obtain sufficient information to support commodity, technology and technical data classification and categorization. We can conduct the regulatory review, and develop the proposed classification or categorization based on the technical content of the proposed item. When necessary, ECS will assist you to obtain the commodity jurisdiction and commodity classification from the Directotate of Defense Trade Controls (DDTC) or the Bureau of Industry and Security (BIS), as appropriate.

The basis for your companys export management and technology transfer control actions is your corporate policy and procedures for the control of company data and commodities. Your ITAR compliance policy and procedures, along with the goals, objectives and responsibilities they establish, provide the authority within the company to make export decisions and conduct export operations, and establish protection for your company against negligent violation of federal law.

We can assist you to identify policy issues and develop policy documentation, as well as create the procedures to implement the policies. We can also help you to create implementation instructions to ensure that company policies are satisfied through proper performance, incident and violation inquiries, and other investigations.

ECS staff has training and experience to conduct sensitive inquiries and investigations into potential export violations. Working on your behalf to conduct discreet inquiries, we can assist you to determine whether a potential export violation exists and identify the basis of that determination. We conduct interviews with knowledgeable persons to determine which events and actions contributed to the potential violation, and collect documentary evidence to support decision-making. In cases where the controllability of the export is unclear, we help make evaluations of commodities or technical data to determine if export regulations or requirements apply. We provide all of these reports and evidence to your company to allow executive management to make decisions, and corporate counsel to determine what further actions may be necessary to resolve the potential export violation situation. In 2020, ECS was approved as the external auditor for a company serving under a Consent Agreement with the U.S. Department of State, Defense Trade Controls Compliance (DTCC).