ST0667

Source text

As written.

[Annex of Compliance Measures] (17) Within twelve (12) months of the date of the Order, NGC will have instituted strengthened corporate export compliance procedures focused principally on NGC's business operations such that: (a) all NGC employees engaged in ITAR-regulated activities are familiar with the AECA, the ITAR, and their responsibilities as an NGC employee; (b) all NGC employees responsible for supervising NGC employees listed in (a), including senior managers of those units, are knowledgeable about the requirements and the underlying policies and principles of the AECA and the ITAR; (c) all NGC export personnel are fully trained and are complying with the terms, conditions, and provisos of authorizations; (d) a formal training program will be instituted for Empowered Officials within NGC, including mandatory training requirements covering the specifics of identifying defense articles and defense services, and procedures for preparing Commodity Jurisdiction (CJ) requests, to be completed within one-hundred eighty (180) days of the date of the Order; and (e) NGC maintains records indicating the names of employees, trainers, and level and area of training received (e.g., providing technical data, use of public domain information in performing defense services, applicability of ITAR to foreign-origin defense articles).

Related

Other DOS standards.