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Understanding the ITAR

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Understanding the ITAR
I was hired three months ago as the secondary Empowered Official of a military contracting company. My main priority has been writing the company’s policy and procedures. The primary EO has told me to ignore the yearly Business Unit (BU) audits and continue with the policy and procedures because there have never been any ITAR problems in the past and because the Bus did not show up for the yearly audit. I agreed and continued writing the policy and procedures. Later on I find out that for the past 5 years on of the Bus has been using the incorrect classification, and the primary EO was notified months ago and told that BU to not worry and continue with production. I also find out the records are missing for that classification. Now my company has become a target of investigation from the US Government and they request all documentation pertaining to the classification of this product.
As the secondary EO I am still an EO and therefore just as responsible as the primary EO. While I have only been employed for three months I believe that I should have stood up to the primary EO and told him that the BU’s should still be audited and that the policy and procedures can wait. If I had audited the Bus I may have found out earlier that the wrong classification was being used and brought it up to the primary EO and urged him to reconsider his stand on ignoring the problem. I could have also helped find the missing documents before they were subpoenaed. While I may not be responsible for the past 5 years I am still just as responsible for the past 3 months. While the Vice President of Operations may not get involved in what the group does, he is also just as responsible for the misplaced/missing documents and the past 5 years’ worth of incorrect classifications.
It is very important that as an EO I have the support of senior management, in this case the Vice President of Operations does not fully support both of the EO’s and this may be one of the big reasons that the

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