--- title: "ITAR Compliance Checklist & Services | TRNSFRM" description: "A 10-point ITAR compliance checklist plus expert help with Technology Control Plans, DDTC registration, and securing controlled technical data." lang: en json-ld: | [ { "@context": "https://schema.org", "@type": "Organization", "name": "TRNSFRM", "alternateName": "TRNSFRM Technology", "url": "https://trnsfrm.tech", "logo": "https://trnsfrm.tech/wp-content/uploads/2021/11/trnsfrm-logo.svg", "image": "https://trnsfrm.tech/og-image.png", "description": "Cybersecurity, compliance, and managed IT services for manufacturers, construction, automotive, and healthcare organizations.", "foundingDate": "2008", "founder": { "@type": "Person", "name": "Jeff Dennis" }, "areaServed": { "@type": "Country", "name": "United States" }, "address": [ { "@type": "PostalAddress", "addressLocality": "Cleveland", "addressRegion": "OH", "addressCountry": "US" }, { "@type": "PostalAddress", "addressLocality": "Columbus", "addressRegion": "OH", "addressCountry": "US" } ], "contactPoint": { "@type": "ContactPoint", "contactType": "customer service", "email": "info@trnsfrm.tech", "areaServed": "US", "availableLanguage": "English" }, "aggregateRating": { "@type": "AggregateRating", "ratingValue": "5.0", "reviewCount": "176", "bestRating": "5", "worstRating": "1" }, "sameAs": [ "https://www.linkedin.com/company/trnsfrm", "https://trnsfrm.tech" ] }, { "@context": "https://schema.org", "@type": "WebSite", "name": "TRNSFRM", "url": "https://trnsfrm.tech", "publisher": { "@type": "Organization", "name": "TRNSFRM" }, "potentialAction": { "@type": "SearchAction", "target": "https://trnsfrm.tech/blog?q={search_term_string}", "query-input": "required name=search_term_string" } }, { "@context": "https://schema.org", "@graph": [ { "@type": "Service", "name": "ITAR Compliance Checklist", "description": "Work through the ten requirements below to see where your ITAR program stands. 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This means hiring or granting access to foreign persons requires proper authorization." } }, { "@type": "Question", "name": "Can ITAR data be stored in the cloud?", "acceptedAnswer": { "@type": "Answer", "text": "Yes, but the cloud environment must meet strict requirements — data must remain within the United States, accessed only by U.S. persons, and the provider must have appropriate security controls. Not all cloud services qualify." } }, { "@type": "Question", "name": "What are the penalties for ITAR violations?", "acceptedAnswer": { "@type": "Answer", "text": "Civil penalties can reach $1,000,000 per violation. Criminal penalties include up to $1,000,000 in fines and 20 years imprisonment. 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If anything you design, build, or store appears on it, ITAR applies — including to drawings and specifications." }, { "@type": "ListItem", "position": 2, "name": "Register with DDTC", "description": "Manufacturers, exporters, and brokers of defense articles must register with the Directorate of Defense Trade Controls and renew annually. Confirm your registration is current and the responsible officer is correct." }, { "@type": "ListItem", "position": 3, "name": "Appoint an Empowered Official", "description": "Name a U.S. person with the authority to sign license applications and stop non-compliant shipments, and document that authority in writing." }, { "@type": "ListItem", "position": 4, "name": "Write and maintain a Technology Control Plan", "description": "Your TCP defines who may access ITAR-controlled technical data, how access is granted and revoked, and how violations are reported. It should be a live document, not a one-time file." }, { "@type": "ListItem", "position": 5, "name": "Verify U.S.-person status for everyone with access", "description": "Disclosing controlled technical data to a foreign national — even an employee working in your own facility — is a deemed export. Confirm status at hire and re-verify when roles change." }, { "@type": "ListItem", "position": 6, "name": "Segregate ITAR data in your IT environment", "description": "Controlled technical data should live in an access-restricted enclave with logging, not on a general file share. Confirm which folders, drives, and repositories are in scope." }, { "@type": "ListItem", "position": 7, "name": "Confirm your cloud and email meet ITAR hosting rules", "description": "Data must remain in the United States and be accessible only to U.S. persons, including provider support staff. Standard commercial Microsoft 365 typically does not qualify — GCC High or an equivalent does." }, { "@type": "ListItem", "position": 8, "name": "Control physical access to controlled areas and media", "description": "Visitor logs, escort policy, badge control, marked storage for drawings, and secure destruction of printed technical data all need to be in place and evidenced." }, { "@type": "ListItem", "position": 9, "name": "Train employees on ITAR obligations annually", "description": "Everyone who touches controlled data should be able to recognize a deemed export and know the escalation path. Keep signed training records." }, { "@type": "ListItem", "position": 10, "name": "Run internal audits and keep records for five years", "description": "ITAR requires export records be retained for five years. Audit your license usage, shipments, and access logs on a set schedule so a DDTC inquiry doesn't become a scramble." } ] }, { "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://trnsfrm.tech/" }, { "@type": "ListItem", "position": 2, "name": "Compliance Frameworks", "item": "https://trnsfrm.tech/governance" }, { "@type": "ListItem", "position": 3, "name": "ITAR Compliance Checklist", "item": "https://trnsfrm.tech/frameworks/itar" } ] } ] } ] --- [Back to Home](/)Get ITAR Compliant ITAR Compliance # ITAR Compliance Checklist Work through the ten requirements below to see where your ITAR program stands. Each item is something a DDTC review or a prime's supply-chain audit will ask you to evidence — and each one we can help you close. Get ITAR Compliant Book a 30-minute, no-obligation risk discovery call. You keep the written snapshot either way ## The 10-Point ITAR Compliance Checklist Go item by item. If you can't produce evidence for one within a day, treat it as an open gap. 1. 1 ### Confirm whether you're subject to ITAR Check your products, components, and technical data against the United States Munitions List (USML). If anything you design, build, or store appears on it, ITAR applies — including to drawings and specifications. 2. 2 ### Register with DDTC Manufacturers, exporters, and brokers of defense articles must register with the Directorate of Defense Trade Controls and renew annually. Confirm your registration is current and the responsible officer is correct. 3. 3 ### Appoint an Empowered Official Name a U.S. person with the authority to sign license applications and stop non-compliant shipments, and document that authority in writing. 4. 4 ### Write and maintain a Technology Control Plan Your TCP defines who may access ITAR-controlled technical data, how access is granted and revoked, and how violations are reported. It should be a live document, not a one-time file. 5. 5 ### Verify U.S.-person status for everyone with access Disclosing controlled technical data to a foreign national — even an employee working in your own facility — is a deemed export. Confirm status at hire and re-verify when roles change. 6. 6 ### Segregate ITAR data in your IT environment Controlled technical data should live in an access-restricted enclave with logging, not on a general file share. Confirm which folders, drives, and repositories are in scope. 7. 7 ### Confirm your cloud and email meet ITAR hosting rules Data must remain in the United States and be accessible only to U.S. persons, including provider support staff. Standard commercial Microsoft 365 typically does not qualify — GCC High or an equivalent does. 8. 8 ### Control physical access to controlled areas and media Visitor logs, escort policy, badge control, marked storage for drawings, and secure destruction of printed technical data all need to be in place and evidenced. 9. 9 ### Train employees on ITAR obligations annually Everyone who touches controlled data should be able to recognize a deemed export and know the escalation path. Keep signed training records. 10. 10 ### Run internal audits and keep records for five years ITAR requires export records be retained for five years. Audit your license usage, shipments, and access logs on a set schedule so a DDTC inquiry doesn't become a scramble. [Score yourself on the full 47-point checklist](/compliance-checklist) ## Who Needs ITAR Compliance? Manufacturers of defense articles, weapons systems, or military components Aerospace and defense contractors and subcontractors Companies providing defense services or technical data to foreign nationals Engineering firms with access to controlled technical drawings or specifications IT providers hosting or processing ITAR-controlled data Any organization on the USML (United States Munitions List) supply chain ## Why It Matters ### Avoid Criminal Penalties ITAR violations carry severe consequences — up to $1M per violation in civil fines, criminal penalties including imprisonment, and debarment from future contracts. ### Protect Controlled Data Ensure defense-related technical data, blueprints, and specifications are only accessed by authorized U.S. persons with proper safeguards in place. ### Maintain Contract Eligibility Defense primes require ITAR compliance from their supply chain. Stay eligible for contracts involving defense articles and technical data. ## How TRNSFRM Gets You There 1 ITAR compliance assessment to identify gaps in your current handling of controlled technical data and defense articles. 2 Technology Control Plan (TCP) development to govern access to ITAR-controlled information within your organization. 3 IT infrastructure review — ensuring cloud, email, storage, and collaboration tools meet ITAR data handling requirements. 4 Employee training on ITAR obligations, deemed exports, and proper handling of controlled technical data. 5 DDTC registration support and guidance on State Department licensing requirements. 6 Ongoing compliance monitoring and audit preparation to maintain your ITAR program as regulations evolve. ## Frequently Asked Questions ### What is ITAR? ### What is a deemed export under ITAR? ### Can ITAR data be stored in the cloud? ### What are the penalties for ITAR violations? ### How does ITAR relate to CMMC and NIST? ## Other frameworks & resources [ ### CMMC Level 2 Definitive Guide Deep-dive on controls, cost, and process. ](/guides/cmmc-level-2)[ ### CMMC DoD contractor certification. ](/frameworks/cmmc)[ ### NIST 800-171 Federal contractor controls. ](/frameworks/nist)[ ### ISO 27001 International ISMS certification. ](/frameworks/iso-27001)[ ### HIPAA Healthcare PHI protection. ](/frameworks/hipaa)[ ### FTC Safeguards Auto dealer & finance rule. ](/frameworks/ftc-safeguards)[ ### Free Compliance Checklist Score yourself in 10 minutes. ](/compliance-checklist)[ ### Case Studies Real certification outcomes. ](/case-studies)[ ### vCISO Leadership Strategic security guidance. ](/vciso) ![Jeff Dennis, Founder & CEO of TRNSFRM](/assets/jeff-dennis-DHbKudnK.png) A note from our CEO > “Frameworks like CMMC, NIST, and HIPAA aren't just paperwork — they're the difference between winning the next contract and losing it. We've walked dozens of organizations through certification. Let's talk about your path.” Jeff Dennis Founder & CEO, TRNSFRM Talk to Jeff about your framework ## Ready to Get Compliant? No pressure. No sales pitch. Just a conversation with an expert to map out your risks, gaps, and next steps. Get ITAR Compliant Not ready to book? Get Your Cyber Score — it's free. [Call Now](tel:+18777776855)Book Call