ST0812

Source text

As written.

(13) Respondent agrees to continue to implement a comprehensive and reasonably uniform automated export compliance system throughout Respondent's operating divisions, subsidiaries and business units engaged in ITAR-regulated activity to strengthen Respondent's internal controls for ensuring compliance with the AECA and the ITAR, unless for certain operating divisions, subsidiaries and business units involved in limited ITAR-regulated activity the Director, DTCC approves an exception. 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 Respondent'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. This system will also provide for automated management of compliance with ITAR Part 124 agreements. Respondent will enable DTCC to access the system when on site or be provided information from the system upon request or both. Respondent 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 DTCC may exercise this authority pending the institution of this system.

Related

Other DOS standards.