marcus evans: Determining ITAR License Requirements With Bob
Schuettler, Director, Corporate Export Licensing at ATK
ALEXANDRIA, VA -- (Marketwire) -- 12/04/12 -- With the increase in
foreign trades, export reform remains an essential element for the
economic success of the United States. Compliance with ever-evolving
export regulations will be essential if US companies want to compete
in the global market place. Understanding regulatory updates within
ITAR, including product classification, brokering definitions,
license exemptions and electronic data transfers will be necessary
for improving operation efficiency and maintaining business
marcus evans had the privilege to hear from Bob Schuettler before the
upcoming 3rd Annual Advanced ITAR Compliance Conference. Below he
shares with us his perspective on key issues facing the approval
process when completing an ITAR license application, as well as
challenges in export controls and implementing ITAR into internal
policies within the organization.
Bob Schuettler joined Alliant Techsystems, Inc. in March 2011 as
Director, Corporate Export Licensing. In this role, he is responsible
for representing ATK's interests in effecting changes to
export/import laws and regulations; engaging the USG and industry
associations on behalf of ATK; formulating export/import reports to
the USG; maintaining the corporations export/import registrations;
and providing training, guidance and instruction to employees on
What recent changes to export controls have created the biggest
challenge for you and are there any changes on the horizon that you
would like to know more about?
Bob Schuettler: Based on recent changes to the regulations, the
biggest challenge involves Dual/Third Country National employees of
foreign parties. The changes to the ITAR can be of great benefit, but
the challenge is in two areas: 1) ensuring foreign parties understand
their options and the requirements, and then conveying the
information back to the US Party; and 2) including the correct
language in the Part 124 Agreement.
Professionals are eager to learn more about the proposed changes to
the ITAR regarding Brokers and Brokering Activities. The DDTC has
taken several attempts at changing ITAR Part 129 but all have left
industry discouraged and concerned with the direction the Directorate
What are the biggest challenges that professionals face with licenses
and exemptions? How do you tackle these challenges?
BS: The biggest challenges I see with licenses and exemptions are
ensuring: 1) the parties and commodities are captured in their
entirety; 2) provisos are implemented and those that limit a
transaction don't prohibit the core purpose of the transaction; 3) a
discrete transaction is within the scope and limitations of the
license or exemption; and 4) complete and accurate records are
The best way to tackle these challenges is through communication and
education with your internal customer executing against the license
or exemption. These are not activities that occur once at the outset
of the transaction, instead they must be continuous as the program
matures and new employees join the program.
What obstacles do you face when implementing ITAR into your internal
policies and how important is employee training?
BS: The biggest obstacle when implementing ITAR into internal
policies is awareness and training. Rarely does a policy only affect
the ITAR professionals within an organization; most policies affect
other functional areas. Bringing awareness and training of the policy
to those other areas should start even before the policy is issued.
Employees don't go around looking for policies to read, so if the
policy is to have any hope of being successful and affecting change,
training and awareness are the core of compliance.
What role does technology and data transfer play within ITAR and what
industry efforts are being made to ensure compliance?
BS: Every transaction does, or at least, has the potential to involve
technical data transfer. The means and methods of such transfers are
constantly evolving and expanding. Unfortunately, the ITAR has not
been as nimble or quick in its evolution. Many of the electronic
methods and systems utilized for technical data transfers were not
created with compliance in-mind; rather they were created with the
intent to quickly share information amongst a group. Therefore,
industry applies patches to manage, track and ensure compliance,
which includes paper forms, independent electronic systems or
expensive and customized overlay systems.
What do you believe attendees can gain most from attending this
BS: The conference faculty brings extensive expertise representing
various opinions, backgrounds, and employer size. In addition, the
attendees will hear first-hand experiences of the faculty and the
other attendees. Many of those experiences will mirror challenges the
attendees have encountered themselves or will encounter in their
career. Besides the knowledge gained from the faculty and other
attendees through these shared experiences, the attendees will leave
armed with best practices, lessons learned and knowledge and
confidence to affect changes within their organization and company.
About marcus evans
marcus evans conferences annually produce over 2,000 high quality
events designed to provide key strategic business information, best
practice and networking opportunities for senior industry
decision-makers. Our global reach is utilized to attract over 30,000
speakers annually, ensuring niche focused subject matter presented
directly by practitioners and a diversity of information to assist
our clients in adopting best practice in all business disciplines.
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