Export Controls Compliance: ITAR & the EAR

From the verbatim EAR — jurisdiction, CCL and ECCN, USML and TAR, licenses and exceptions, deemed exports, end-use and end-user controls, compliance and penalties.

Private cohorts & on-site
Format: 2-day (8:30 a.m.–4:30 p.m.)
Level: Advanced
Location: Scheduled on demand · on-site at your facility or a regional venue
Date(s): Not yet scheduled for open enrollment. Get notified when it is, or book it privately for your team.
Includes: Certificate of Completion · printed slide binder · take-home reference text

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One email when dates are set. Or skip the wait: run it as a private cohort, on-site at your plant.

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Faculty

Faculty details for this seminar will be announced with the full schedule.

Fees

Early: $1,895 (payment 4+ weeks ahead)
Standard: $2,095 (check/ACH) · $2,165 (card)

Group discount: $200 off per attendee for 3+ from the same organization.

Also Available

  • Corporate on-site delivery at your facility
  • Private cohort sessions
  • Digital curriculum licensing

Seminar Overview

This seminar is built directly from the primary-source regulations — not summaries of them. Every module is taught from the verbatim text of the Export Administration Regulations (15 CFR Parts 730, 732, 734, 736, 738, 740, 742, 744, 746, 772, and 774, including the full Commerce Control List in Supplement No. 1 to Part 774) and the complete International Traffic in Arms Regulations (Title 22 CFR Parts 120–130, covering the full United States Munitions List). Vendor slide decks paraphrase these documents; we hand you the actual clauses, because export determinations that hold up under audit are made against the regulatory text itself.

Export control exposure is one of the most expensive blind spots in manufacturing and engineering organizations. A single misclassified part, an unlicensed technical-data transfer, or a shipment to a restricted party can trigger civil penalties, criminal exposure, and debarment. Yet most engineering teams have never systematically read the two frameworks that govern their products: which regulation has jurisdiction (ITAR or EAR), what entry on the Commerce Control List or US Munitions List actually captures the item, and what paperwork must exist before anything ships, emails, or gets shown on a screen.

After two days you will be able to triage jurisdiction between the ITAR and the EAR, assign an ECCN from CCL entry parameters, read USML categories and their "specially designed" logic, determine when a license exception is available under Part 740, screen transactions against the Part 744 lists, and build the recordkeeping and procedures that Part 762 and 22 CFR 122.5 demand. This is a rare, proprietary-level regulatory course: the same material taught inside corporate trade-compliance departments, delivered in plain engineering language.

Ideal Learner

  • Export compliance managers and trade compliance specialists who must make (or defend) classification decisions
  • Engineering and program managers whose products, software, or technical data may be controlled
  • Manufacturing and quality engineers at aerospace, defense, and dual-use suppliers
  • Contract manufacturers and machining suppliers quoted on defense-adjacent work
  • Legal and procurement staff who need working fluency in ITAR/EAR mechanics

Learning Objectives

  • Determine whether an item falls under the ITAR (22 CFR 120–130) or the EAR (15 CFR 730–774) using the Part 732 decision steps
  • Assign an ECCN by reading actual Commerce Control List entries, including parameter-based controls and EAR99 fallback
  • Identify when a USML category captures an item and how "specially designed" and technical data control work
  • Evaluate license exceptions under Part 740 and ITAR exemptions under 22 CFR 125.4 against their eligibility conditions
  • Screen orders and employees against Part 744 lists and recognized "red flags," and control deemed-export exposure
  • Construct a compliant recordkeeping and procedure set under 15 CFR Part 762 and ITAR recordkeeping rules

Consulting Sessions

Seminar attendees can sign up for individual consulting sessions with the instructor. Sessions are free for registered attendees, first-come first-served — sign up when registering by calling 248-539-0473 or during the seminar.

Seminar Outline

  • Anatomy of the EAR: Parts 730 (scope), 732 (steps to classification), 734 (what is "subject to the EAR"), 736 (general prohibitions)
  • Anatomy of the ITAR: Title 22 CFR Parts 120–130 — definitions, USML, registration, licensing, exemptions, brokering
  • U.S.-origin content, foreign-made items incorporating controlled U.S. content, and re-export logic
  • Defense articles vs. dual-use items; commodity jurisdiction and how items move between regimes
  • **Compliance Case Study: jurisdiction triage for a commercial component with a defense application**
  • CCL architecture: Categories 0–9, product groups A–E, and the ECCN format
  • Reading Supplement No. 1 to Part 774 entry-by-entry: parameter thresholds, Notes, and associated software/technology entries
  • What EAR99 does and does not mean; when EAR99 items still need licenses
  • De minimis thresholds (§734.4) and the direct product rules (§734.9)
  • **Exercise 1: ECCN classification worksheet — machined parts and electronics against CCL entry parameters**
  • USML categories I–XXI: what each captures, in the regulation's own words
  • "Specially designed" and the catch-all notes; how design intent converts commercial parts into defense articles
  • Technical data and defense services: drawings, specifications, training, and engineering support
  • Registration obligations (22 CFR Part 122) and who must register even without exports
  • **Exercise 2: USML vs. CCL triage on three sample part families**
  • General prohibitions and the license determination sequence
  • License exceptions under Part 740: eligibility conditions, destination limits, and documentation
  • ITAR licensing: DSP license applications, technical assistance and manufacturing license agreements (Parts 123–124), exemptions under 22 CFR 125.4
  • Part 742 control policy factors and Part 746 embargo/sanctioned destinations
  • **Worked example: Part 740 exception eligibility walk-through using the exception's own condition text**
  • "Release" of controlled technology: visual disclosure, oral exchange, and practical application (§734.13–§734.15)
  • Deemed exports to foreign-person employees and contractors; screening and license pathways
  • Fundamental research exclusion (§734.8), published information (§734.7), and education/instruction exclusions
  • Plant-floor controls: drawing distribution, email, supplier transfers, and visitor access
  • **Case study: deemed-export exposure inside an engineering department with foreign-national staff**
  • Part 744 restricted-party lists: Entity List, Denied Persons List, Unverified List, Military End User list
  • End-use-based prohibitions and the Military End Use/User rule
  • Know-your-customer guidance and the "red flags" of Supplement No. 3 to Part 732
  • Restricted-party screening in the order-to-ship process; handling screening hits
  • **Exercise 3: order-screening drill — ship/hold decisions on realistic customer scenarios**
  • BIS Export Compliance Program elements and ITAR compliance program expectations
  • Recordkeeping under 15 CFR Part 762 and ITAR recordkeeping: what records, for how long, retrievable how fast
  • Voluntary self-disclosures: when to file, how enforcement values them, penalty drivers
  • Building desk procedures: classification, screening, licensing, shipping, and audit trail
  • **Worked example: mapping a company's export workflow onto the Part 732 ten-step process**
  • End-to-end determination: new product review → jurisdiction → classification → license/exception → screening → shipment record
  • The failure patterns behind most enforcement actions: misclassification, missed "specially designed" analysis, unlicensed technology transfers
  • **Exercise 4 (capstone): full export determination for a multi-level bill of materials**

More in Track D — Reliability, Statistics & Compliance

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