Ensuring ITAR Compliance: Key IT Strategy Considerations for an ITAR Audit

The International Traffic in Arms Regulations (ITAR) is a complex set of export regulations that control the export and import of defense articles and services in the United States. ITAR compliance is critical for any company that manufactures, exports, or imports defense articles or services listed on the United States Munitions List (USML).

ITAR regulations extend beyond physical defense articles and also control technical data related to defense articles. This means ITAR also applies to intangible data such as blueprints, schematics, training manuals, software code, and other information required for the production or operation of a defense article.

Given the scope of ITAR, it is essential for IT leaders and professionals at ITAR-regulated companies to build an IT strategy and infrastructure that supports robust ITAR compliance ahead of an ITAR audit. Here are three key areas to focus on:

Access Controls and Data Security
At the foundation of any solid ITAR compliance strategy are strong access controls and data security policies. IT teams need to ensure only authorized individuals can access technical data controlled under ITAR. This requires secure authentication methods, compartmentalized access permissions, and robust cybersecurity protections like firewalls and intrusion detection systems.

All ITAR-controlled technical data should be properly marked indicating it is controlled. IT teams must work to minimize the risk of unauthorized access or data leaks through comprehensive data security and access management policies.

System Segregation

ITAR has system infrastructure requirements related to the storage, processing, and transmission of controlled technical data. IT teams must segregate ITAR-controlled data and systems from other corporate systems. This may mean having physically separated networks, servers, and storage for ITAR data.

Proper network segregation configuration is a key technical control during an ITAR audit. It demonstrates your ability to restrict access to sensitive data to only personnel with a legitimate need to know.

Personnel Training

Having the right policies and security controls is useless without proper training for your personnel. Anyone with potential access to ITAR-controlled data should complete training on ITAR regulations and compliance requirements.

IT teams should implement access controls restricting users from accessing sensitive data until they complete required ITAR training. Ongoing security awareness training is also critical to maintaining compliance in the face of evolving threats.

An Ounce of ITAR Prevention

Implementing the appropriate IT strategy and controls before an ITAR audit is critical to demonstrating diligent compliance. The right blend of security policies, access controls, data segregation, and personnel training can help companies efficiently prove compliance during an audit.

Being proactive also reduces the risk of penalties and disruptions to business operations if violations were to occur. With the right IT foundation supporting your overall ITAR compliance program, your company can confidently navigate the next ITAR audit.

Ready to Review Your ITAR compliance posture?

We can provide recommendations customized to your organization's needs and compliance gaps. Contact us today schedule a call. You can email our team at info@aislabs.com.