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Company Overview – March 12, 2015
Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing ITAR & EAR Training For Employees Working with ITAR &EAR Controlled Technology
ITAR / EAR Security Briefing Company Overview March 12, 2015 - - PowerPoint PPT Presentation
ITAR / EAR Security Briefing Company Overview March 12, 2015 - - PowerPoint PPT Presentation
ITAR / EAR Security Briefing Company Overview March 12, 2015 INTRODUCTION ITAR & EAR Training For Employees Working with ITAR &EAR Controlled Technology I nternational E xport T raffic in A dministration A rms R egulations R
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
Cumbernauld, Scotland
NATIONAL SECURITY
Something of Value… Country Job Freedom Family
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
TYPES OF NATIONAL SECURITY INFORMATION Unclassified Sensitive Information
SECRET
CONFIDENTIAL
TOP SECRET
RESTRICTED FOR OFFICIAL USE ONLY NATO CNWDI COMSEC
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
TWO LISTS GOVERNING EXPORTS
USML: US Munitions List
Administered by the Department of State with concurrence of the Department of Defense
Defense Articles and Defense Services items controlled under the ITAR
Items controlled under USML (categories I-XXI) CCL: Commerce Control List
Administered by the Department of Commerce under the Bureau of Industry and Security
Commercial items controlled for export under the EAR
Items controlled by ECCN (numeric, alpha, numeric numbers – i.e. example: 3A001,5A991,3A611.y
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
ITAR SECURITY BRIEFING
What is ITAR?
Procedures for processing ITAR orders & handling technical data
Reporting obligations and requirements
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
ITAR IS…
International T raffic and Arms (ITAR) controls defense articles, defense services, and related technical data, including most non-sporting weapons
Protecting ITAR Information to protect the War Fighter
Regulated by the Department of State Directorate of Defense T rade Controls(DDTC)
Insures Arms and Protected T echnology does not fall into the wrong hands
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHO IS A U.S. PERSON?
US citizen
Permanent resident with a “green card”
Designated an asylee or refugee
A temporary resident under amnesty provisions
Entity incorporated to do business in the U.S.
* but the company itself may have foreign persons employees
Under ITAR 22 CFR § 120.15
= U.S. PERSON
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHO IS A FOREIGN PERSON
A “Foreign Person” is:
Not a U.S. citizen, permanent resident, or protected person (political asylee)
Definition of “person” includes corporations and other business associations, as well as natural persons Why is this important?
Deemed Exports
Physical or electronic access to technical data by foreign national in the U.S.
Oral exchanges of information in the U.S.
Visual inspection by foreign national of U.S.-origin equipment and manufacturing operations
Observations by foreign persons of application to situations of personal knowledge or technical experience
I-129 Forms
Under ITAR 22 CFR § 120.16
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHAT IS “TECHNICAL DATA”?
Information required to design, develop, produce, manufacture, assemble, operate, repair , test, maintain or modify defense articles, e.g.:
- Blue prints
- Drawings
- Photographs
- Instructions
- Plans
- Documentation
Classified information relating to defense articles and defense services on the USML and 600 series items controlled by the Commerce Control List
Information covered by an Invention Secrecy Order
Software directly related to a defense article
120.45(f)Software includes but is not limited to the system functional design, logic flow, algorithms, application programs, operating systems, and support software for design, implementation, test, operation, diagnosis and repair
But does not include information in the public domain
Under ITAR 22 CFR § 120.10
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
TECHNOLOGY TARGETS
Electronic Systems and Subsystems
Integrated Circuits
Radar Electronics
Guidance & Navigation Electronics
Collection Methods
Phishing Requests
Screen Photos with Cell Phone
Image Drives in Conference Room
Stealing Data on Laptop in Hotel Room
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
ITAR COMPLIANCE TIMELINE
Corporate Systems Transition
Network Bridge Server Upgrade Cameras Badge Readers Badge Upgrade Molex Email Accounts & Intranet Upgrade ITAR Technical Data Security Training Physical Security Training Watch Dox Training Veronis Training Universal PDM Tool Training
ITAR Training Requirements
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHO RECEIVES ITAR TECHNICAL DATA ACCESS? PERMISSION
Administrative action, usually involving a USA Person check and permission granting by your supervisor
NEED TO KNOW
Duties and projects that require you to work with ITAR sensitive material
+ =
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
ITAR DATA SECURITY PRACTICES
Vigilance
Security Awareness Training
Formal
Impromptu Standard Procedures
Working with
T ransmitting (Can’t be emailed as it is stored in the Cloud)
Securing
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHAT IS EAR?
Export Administration Regulations Administered by The Department of Commerce In essence, the EAR control any item warranting control
that is not exclusively controlled for export, reexport, or transfer (in-country) by another agency of the U.S. Government or otherwise excluded from being subject to the EAR pursuant to Sec. 734.3(b) of the EAR.
Controls Dual-use items* * dual-use" item is one that has civil applications as well as terrorism and military or weapons of mass destruction (WMD)-related applications
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
WHAT IS CONTROLLED TECHNOLOGY UNDER THE EAR?
The US Export Administration Regulations define technology under the EAR §772 as:
“T echnology” – is specific information necessary for the “development,” “production,” or “use” of a product. The information takes the form of “technical data” or “technical assistance.”
“T echnical assistance” may take forms such as instruction, skills training, working knowledge, consulting services.
“T echnical data” may take forms such as blueprints, plans, diagrams, models, formulae, tables, engineering designs and specifications, manuals and instructions written or recorded on other media or devices such as disk, tape, read-only memories.
Under the Export Administration the releasing of controlled technology to a foreign person is informally referred to as a Deemed Export. Release of controlled technology to foreign persons in the U.S. are "deemed" to be an export to the person’s country or countries of nationality
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
DEEMED EXPORT UNDER THE EAR
T
echnology is "released" for export when it is available to foreign nationals for visual inspection (such as reading technical specifications, plans, blueprints, etc.); when technology is exchanged
- rally or electronically or when technology is
made available by practice or application under the guidance of persons with knowledge of the technology
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
HOW DO I MANAGE CONTROLLED TECHNOLOGY?
TRAINING-AWARENESS
PROPER IDENTIFICATION/CLASSIFICATION
- Determine jurisdiction -subject to the ITAR or EAR?
TECHNOLOGY CONTROL PLAN (TCP) Develop and implement T echnology Control Plan
Company wide, project specific, or employee specific?
CONTRACT CLAUSES - Include robust export compliance clause in
relevant contract or obtain compliance certifications
Each party to retain responsibility for compliance with export control and economic sanctions laws
Require parties to provide notice prior to transferring controlled items
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
SECURITY PROCEDURES AND DUTIES
It is your personal responsibility to know that the person you are dealing with is both properly permissioned and has a need to know
You must never reveal or discuss ITAR ,EAR or Sensitive/controlled technology information with anyone other than those that are properly permissioned and have a need to know
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
PROTECTION OF ITAR & EAR INFORMATION:
Make sure secure Screen Saver installed and working (if not submit helpdesk request)
Know and use correct email procedures for ITAR &EAR sensitive data transmission Always use ZIP and encrypting before sending ITAR & EAR sensitive data to customers and vendors
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
SALES
CURRENT ITAR DATA FOLDER STRUCTURE
ITAR Data Folder Structure: Appendix C X:\ ITAR JOB FILES QUOTES ENGINEERING WIP DEVELOPMENT PROJECTS PROCESS
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
FUTURE TOOL – RECEIVING/TRANSMITTING ITAR DATA
Use current encryption process
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
CONTROL OF CUSTOMER DATA POLICY AND PROCEDURE
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
UNDERSTAND YOUR RESPONSIBILITIES!
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
UNDERSTAND YOUR RESPONSIBILITIES!
Minor Violations MAY Include:
Verbal Counseling
Written Counseling
Suspension/T ermination Major Violations MAY Include:
Same as minor violations
Arrest
Imprisonment or fines
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
YOU MUST REPORT…
Loss, compromise, (or suspected loss or compromise) of ITAR Sensitive or proprietary information
IF YOU SEE SOMETHING SAY SOMETHING TO YOUR MANAGER
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
YOU MUST REPORT…
All suspicious contacts with known or suspected intelligence officers from any country, or any contact which suggests the employee may be the target of an attempted exploitation by the intelligence services of another country
REPORT TO YOUR MANAGER
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
YOU MUST REPORT…
If at any time you are UNSURE about what you can or can’t do
ASK YOUR MANAGER
How can I help?
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
SUMMARY
Ensure that you are suitably trained to administer the requirements of the ITAR or EAR Protecting ITAR or EAR Information to Protect the War Fighter
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Company Overview – March 12, 2015 ITAR, EAR Controlled Technology and Security Briefing
PROTECTION OF ITAR & EAR INFORMATION:
STOP THINK ASK
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ITAR & EAR Compliance Questions?
» Joe Bagliere
(805) 383-8490 joe.bagliere@molex.com Office: Email: Compliance & Contract Manager
THANK YOU!
Contact ISI to engage on your next project:
» Bob Garon
(630) 707-0991 bob.garon@molex.com Cell: Email: Midwest USA
» Brian Witzen
(919) 633-0798 brian.witzen@molex.com Cell: Email: Eastern USA (714) 993-9618 (714) 261-3733 dave.gagnon@molex.com Office: Cell: Email: Western USA
» Dave Gagnon
741 Flynn Road / Camarillo, California 93012 (805) 482-2870 www.ISIPKG.com Address: Phone: Website: