ST0616

Source text

As written.

(14) ITT agrees to continue with the implementation of the comprehensive automated expo~ compliance system to strengthen ITT Corporation's internal controls for ensuring compliance with the Act and Regulations. The system concept as outlined under the November 1, 2004 Consent Agreement and the ITT April 21, 2005 "White Paper", was approved by DTCC on July 26, 2005. ITT will provide to DTCC an update outlining the status of ITT' s automated export compliance system. This system will track the decision process from the initiation of a request for potential export authorization or clarification of an existing authorization to its conclusion that will reflect ITT's ability to oversee and monitor export activity. This system will cover the initial identification of all technical data and technical assistance in any form proposed to be disclosed to any foreign persons and will be accessible to DTCC upon request. ITT understands that DTCC may, in its sole discretion, not authorize use of exemptions for shipments of unclassified technical data in furtherance of a technical assistance agreement, and that DDTC may exercise this authority pending the institution of this system. ITT will develop with the Corporation's email system a means of alerting users to the AECA and ITAR requirements on electronic transmissions of ITAR technical data. This alert system will include a login banner that is displayed when any employee logs onto the system, which will describe AECA and ITAR requirements and offer contact information for anyone who has further questions. In order to prevent unintentional or accidental transmissions to unauthorized recipients, ITT will also provide training to all employees to ensure that any type of electronic transmissions of ITAR controlled technical data are sent in accordance with ITT' s export compliance policies and procedures.

Related

Other DOS standards.