Once permission has been granted for the ITAR agreement, several compliance tasks must be performed, including: rule implementation, enforcement of agreements, file notifications and reports with DDTC/DTCL, balance management, file changes and record management. Question #1: Can a defence item manufactured or manufactured during the duration of an agreement (TAA or GWG) using technical data or defence services received under the agreement be transferred without further DDTC authorization to a foreign person who was not a party to the agreement at the expiry of this agreement? It is important that DDTC enter into an approval agreement with L3Harris in the fall of 2019 for alleged violations of the Arms Export Control Act (“AECA”) and ITAR. One of the 131 alleged ITAR offences contained in the proposed royalty letter was “violation of licence conditions and agreements.”  In particular, the company breached the terms and conditions of the TAAs and GWGs by not submitting: 1) the first export reports;  2) of the agreements reached;  3) annual status declarations;  4) a written statement on the agreements reached;  and 5) annual sales reports;  not only the non-disclosure by DDTC of unsigned agreements.  The exported copy is accompanied by a cover letter containing the applicant`s registration code, contract number and other relevant information. In addition, the cover letter for the exported LGG filing must also contain a copy of the license authorization as well as an original copy and an additional copy of the cover letter that was made after . 124.4 (b) (1) (4) contains the necessary information (for example. B the identity of the foreigner and the parties concerned, the descriptions and estimated value of the defence, restrictions on the transmission of third parties and other quantities of production and disposition). As noted in the Propositiond Charging Letter, L3Harris violated this requirement by failing to “present a written statement accompanying the LWG agreements concluded.”  Response #1: Yes, the continued use and exchange of technical data received through a TAA between previously authorized recipients for the same authorized end-use is in principle permitted even after the termination or expiry of the contract. All transfer conditions or conditions applicable to technical data approved under the TAA continue to apply.
However, if the activity requires the provision of a defence service by a U.S. person, a separate DDTC authorization would be required. Distribution Agreement This type of license is an agreement for the creation of a warehouse or overseas outlet for defense products exported from the U.S. distribution must be located in an authorized distribution area. If the decision to terminate the ITAR agreement has been made, the U.S. applicant must notify DDTC/DTCL in writing no later than 30 days before the expiry date of the agreement. The termination letter must be downloaded into the approved license of the basic agreement and must contain the applicant`s registration code DDTC and contract number. The notice period of a GW and a WDA must be accompanied by a final summary of the sales report or a final summary of the activity. The agreements under the International Traffic in Arms Regulations (“ITAR”) serve as a licensing tool for the transfer of defence, technical data, manufacturing know-how and defence services between a U.S. and a foreign party.
Compliance with the requirements of these agreements is an important element of ITAR compliance, as evidenced by the most important recent approval agreement of L3Harris Technologies, Inc. (“L3Harris” or “The Enterprise”) with the U.S. State Department(“State” Directorate of Defense Trade Controls (DDTC). DSP-73 This application and license is intended for the temporary export of unclassified defence items submitted to ITAR.